Tag Archive for Filing Compliance Procedures for Non-Resident U.S. Taxpayers

Does The IRS Have The Authority to Issue Whistleblower Awards For FBAR Penalties?

Does the IRS have the authority to issue Whistleblower awards under Section 7623(b) to an individual who provides information that results in the assertion of FBAR penalties? In Whistleblower 22231-12W v. Commissioner, T.C. Memo. 2014-157, the Tax Court came close to deciding this issue.

The only reason it stopped short was because the jurisdictional pre-requisite for the Court to act – a determination by the Whistleblower Office on whether to accept or reject the petitioner’s claim – had not yet been made. In other words, because the petitioner’s claim was still pending before the Whistleblower Office, the Tax Court did not have jurisdiction to do anything. Read More

Written by | Posted in FBAR

New Filing Compliance Procedures for Non-Resident U.S. Taxpayers

The IRS is aware that some U.S. taxpayers living abroad have failed to timely file U.S. federal income tax returns or Reports of Foreign Bank and Financial Accounts (FBARs). Some of these taxpayers have recently become aware of their filing obligations and now seek to come into compliance with the law. The Service is announcing a new procedure for current non-residents including, but not limited to, dual citizens who have not filed U.S. income tax and information returns to file their delinquent returns. This procedure will go into effect on Sept. 1, 2012.

Note: On September 30, 2013, FinCEN posted, on their internet site, a notice announcing FinCEN Report 114, Report of Foreign Bank and Financial Accounts (the current FBAR form). FinCEN Report 114 supersedes TD F 90-22.1 (the FBAR form that was used in Read More

Written by | Posted in Expatriate • FATCA • FBAR • Federal • International • OVDP • Tax Fraud/Evasion/Crimes