Entries by Manager

New FBAR Deadline

There has been a lot of confusion surrounding the new FBAR deadline. Since the FBAR is one of the most important US international tax deadlines, it is important to clarify the change in the FBAR filing deadline. What is “FBAR”? FinCEN Form 114, commonly known as FBAR, is the Report of Foreign Bank and Financial […]

Interest Rates for the Fourth Quarter of 2015 and First Quarter of 2016

The IRS underpayment and overpayment interest rates are highly important in US tax law in general, and offshore voluntary disclosures in particular. Not only do these rates determine the interest on additional tax liability on the amended tax returns, but the same rates are sued to determine the PFIC interest rate on “excess distributions”. During the […]

US Tax Return Statute of Limitations and IRC Section 6501(c)(8)

Most tax practitioners are familiar with the general rules of assessment statute of limitation for US tax returns. However, very few of them are aware of the danger of potentially indefinite extension of the statute of limitations contained in IRC Section 6501(c)(8). In this article, I would like to do offer a succinct observation of […]