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 […]
Category: Offshore Accounts/International Tax Disputes
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 […]
Taxpayers that own (or control) offshore bank accounts and other foreign financial assets have a duty to report these assets to the federal government annually. While there are minimum thresholds for taxpayers’ reporting obligations, these thresholds are fairly low—so most high-income and high-net-worth taxpayers will need to comply. Typically, this […]
While the FTX trial has recently been making national headlines, the Internal Revenue Service (IRS), Financial Crimes Enforcement Network (FinCEN), and other federal agencies have been targeting cryptocurrency-related crimes for years. Along with FTX, other exchanges and mixers like Tornado Cash have faced intensive scrutiny as well, and federal authorities […]
The Internal Revenue Service’s (IRS) streamlined filing compliance procedures provide a way for U.S. taxpayers to mitigate the consequences of failing to disclose their foreign financial assets. Taxpayers who qualify to submit a streamlined filing are not subject to failure-to-file, failure-to-pay or accuracy-related penalties and instead pay a five-percent “miscellaneous […]
U.S. taxpayers who own offshore accounts and certain other foreign financial assets have an obligation to disclose these assets to the Internal Revenue Service (IRS)—provided that their value exceeds the IRS’ relatively modest reporting thresholds. Depending on the nature of a taxpayer’s foreign financial assets, this may entail two separate […]
Tax laws are notoriously complicated and confusing. Average taxpayers rarely have a solid grasp on what they need to know, and in some cases, it takes the U.S. Supreme Court to interpret these laws. For instance, the Bank Secrecy Act has been in place since 1970, but interpretive problems still […]
If you are wishing to avoid criminal prosecution and be compliant with The Foreign Account Tax Compliance Act (FATCA) you will need to accurately report on any foreign financial accounts and foreign assets you or your company or business entity holds. In November of 2018, the IRS issued new guidance […]