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Hello and welcome to Sherayzen Law Office Video Blog. My name is Eugene Sherayzen; I’m an International Tax Attorney and owner of Sherayzen Law Office, Ltd. Today, I’m on a train in Eastern Europe and this is the perfect time to share my thoughts about unfiled FBARs. What I’m talking about is a situation where […]
Now FATCA, when it came out in 2010, was a revolutionary piece of legislation. It completely changed not only US Tax Compliance but the entire landscape of International Tax Compliance. After FATCA, we have OECD countries developing a Common Reporting Standard, the CRS to which the US did not join for very interesting reasons; that […]
Form 8938, even though it does not share the same amount of penalties (and we will talk about penalties in a little bit later), still it’s importance is much more significant than that of FBAR. The reason being is that not only are the US Persons required to report their Foreign Financial Accounts, which is […]
In order to force ‘Specified Persons‘ to report all of this; there’s a set of penalties. ‘Failure to File’: $10,000 per form. If the IRS sends out a notice and within 90 days the person still does not file the form the penalty accumulates at about $10,000 per month capped at $50,000. Accuracy-related penalty: if […]
In my handout you see that here the general definition of under the ‘Specified Domestic Entity’ table we see the general definition here directly from the Treasury Regulations 1.6038D-6(a) and it says: ‘A specified domestic entity is a domestic corporation, a domestic partnership or a trust described in IRC Section 7701(a)(30)(E), if such a corporation, […]