Under federal law, U.S. taxpayers who hold qualifying offshore accounts (and certain other foreign financial assets) must report these assets to the U.S. Treasury on an annual basis. In many cases, taxpayers must file two separate forms—with two separate federal entities—to meet their reporting obligations. One of these forms, the […]
Category: Offshore Accounts/International Tax Disputes
Each year, we publish dozens of articles with insights for high-income and high-wealth U.S. taxpayers on our blog. This past year was no exception. Here is a look back at some of the key compliance insights Texas IRS dispute lawyer Lawrence Brown shared in 2024: Resolving Offshore Account Disclosure Violations […]
U.S. taxpayers who own offshore accounts have annual filing obligations that do not apply to other taxpayers. As failing to meet these filing obligations can potentially trigger civil or criminal penalties, it is imperative that offshore account holders prioritize compliance. With the end of 2024 fast approaching, what do offshore […]
High-income and high-net-worth U.S. taxpayers who have assets held overseas have an obligation to report these assets to the U.S. Treasury Department. Specifically, taxpayers must report their offshore accounts to the Treasury’s Financial Crimes Enforcement Network (FinCEN), and they must report their “foreign financial assets” (which include offshore accounts) to […]
The IRS’s Voluntary Disclosure Practice (VDP) and its Streamlined Filing Compliance Procedures both provide ways for high-income and high-net-worth taxpayers to proactively resolve issues related to the disclosure (or non-disclosure) of their offshore assets. But, the VPD and Streamlined Filing Compliance Procedures are very different—each being subject to its own […]
The Voluntary Disclosure Practice (VDP) provides an avenue for high-income and high-net-worth taxpayers to resolve significant federal tax controversies without facing criminal prosecution. Administered by IRS Criminal Investigation (IRS CI), the VDP is a long-standing program that allows eligible taxpayers to mitigate their exposure and settle with the IRS—provided that […]
High-income and high-net-worth taxpayers who have assets offshore must report these assets to the U.S. government annually. For most, this means filing both IRS Form 8938 to comply with the Foreign Account Tax Compliance Act (FATCA) and a Report of Foreign Bank and Financial Accounts (FBAR) to comply with the […]
Most U.S. taxpayers who own offshore accounts have a legal obligation to disclose these accounts to the federal government on an annual basis. In most cases, taxpayers must separately report their offshore accounts to the Internal Revenue Service (IRS) and the Financial Crimes Enforcement Network (FinCEN), which is also part […]
The Internal Revenue Service (IRS) recently launched its highly anticipated Employee Retention Credit Voluntary Disclosure Program (ERC VDP). Under the ERC VDP, eligible businesses can resolve improper ERC claims without liability for interest or penalties. However, filing under the ERC VDP can be risky, and it isn’t the best option […]
Taxpayers who own qualifying offshore accounts and other foreign financial assets have an obligation to disclose these assets to the federal government on an annual basis. As we move into 2024, it is important for high-income and high-net-worth taxpayers to ensure that they have a clear understanding of their reporting […]