On December 4, 2018, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced a further extension of time for Report of Foreign Bank and Financial Accounts (FBAR) filings for certain individuals with signature authority over, but no financial interest in, one or more foreign financial accounts. The extension was granted in light of the notice
Transparency Tide or Tsunami? The New Wave of Global Reporting Rules and IRS Tools To Unearth Foreign Financial Accounts
On December 12, 2018, Matthew D. Lee will participate in a ABA Tax Section webinar entitled “Transparency Tide or Tsunami? The New Wave of Global Reporting Rules and IRS Tools To Unearth Foreign Financial Accounts.” This webinar will address the latest developments with respect to the foreign financial asset reporting rules and recent offshore tax
Despite Closure of OVDP, Offshore Tax Evasion Crackdown Marches On
On September 29, 2018, the Internal Revenue Service closed for good the long-running Offshore Voluntary Disclosure Program (OVDP), its hugely successful tax amnesty program for undisclosed offshore financial assets. Since March 2009, the IRS has maintained an offshore voluntary disclosure program in some form or fashion, and more than 56,000 taxpayers have taken advantage of
Internal Revenue Service Reminds Taxpayers to Report Offshore Bank Accounts on FBAR Form
The Internal Revenue Service has issued its annual reminder to taxpayers that they report their foreign assets on their individual tax returns due on April 17, 2018. Individuals with offshore assets such as bank accounts generally have up to three reporting obligations with respect to such assets. First, individuals with foreign bank accounts must answer
Offshore Tax Evasion Rounds Out IRS Annual “Dirty Dozen” for 2018
The Internal Revenue Service has issued a warning to taxpayers about avoiding taxes by hiding money or assets in unreported offshore accounts, a tax scam that remains on the annual “Dirty Dozen” for 2018. Offshore tax compliance has been a major focus for the IRS in recent years, and taxpayers should remain wary given the
Offshore Accountholders Beware: New DOJ Sentencing Policy for FBAR Cases Is a Game-Changer
The Justice Department’s Tax Division has recently announced a major policy shift that will invariably result in longer jail sentences for individuals convicted of failing to report their offshore bank accounts on the FBAR form. Since 2009, the Justice Department and Internal Revenue Service have aggressively prosecuted individuals with secret offshore bank accounts, and the
FinCEN Clarifies Upcoming FBAR Due Date for Calendar Year 2017
Today the Treasury Department’s Financial Crimes Enforcement Network posted a “FBAR Due Date Clarification” on its website, which confirms that the annual filing deadline for FinCEN Form 114 (commonly referred to as the FBAR form) is April 15. in 2015, Congress passed a law changing the FBAR due date from June 30 to
FinCEN Announces Yet Another FBAR Filing Extension for Certain Financial Professionals
Last week the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) again extended the deadline for certain financial professionals to file foreign bank accounting reporting forms known as FBARs. In FinCEN Notice 2017-1, FinCEN announced a further extension of time for certain FBAR filings in light of proposed rules issued on March 10, 2016. Specifically,
On Eve of “Paradise Papers” Release, At-Risk Individuals Should Consider Immediate Action to Mitigate Potential for Criminal Prosecution
Tomorrow morning (November 17) the International Consortium of Investigative Journalists (ICIJ) is set to release publicly the first set of comprehensive data from the recent “Paradise Papers” leak. The initial data will include information on approximately 25,000 offshore entities and trusts registered in more than 30 jurisdictions, primarily from client records of the Appleby law
Could U.S. Tax Reform Include An End to Citizenship-Based Taxation?
With tax reform a hot topic in Washington, key Republican lawmakers in Congress are considering a major change to the U.S. tax system: eliminating citizenship-based taxation and moving to a residence-based system, according to a report in today’s Financial Times (subscription required) and also reported by Bloomberg. Under current law, U.S. citizens are taxed