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In response to numerous requests made by the international tax attorneys and individual FBAR filers of the Reports of Foreign Bank and Financial Accounts (FBARs) jointly with spouses, or wish to submit them via third-party preparers, the Financial Crimes Enforcement Network (FinCEN) introduced FinCEN Form 114(a), Record of Authorization to Electronically File FBARs. A copy […]
On October 1, 2013, in response to various requests from FBAR tax lawyers and accountants, FinCEN updated the online FBAR filing form. There are various new technical additions and a much friendlier user interface, but the inclusion of the explanation for the delay in FBAR filing is definitely the key new feature for the FBAR […]
Since the early 2000s, the IRS has engaged in a multi-layered effort to enforce U.S. tax laws overseas, in particular (at least from the perspective of an offshore voluntary disclosure attorney) curb tax evasion in Switzerland with the emphasis on undisclosed Swiss financial accounts (mainly FBAR compliance). In 2008, the U.S. Department of Justice (DOJ) […]
There is a great confusion among international tax attorneys and Offshore Voluntary Disclosure Program (OVDP) applicants with respect to the OVDP Offshore Penalty and how it differs from the FBAR penalties. I already described in another article the OVDP penalties. In this article, I would like to compare and contrast some of the major features […]
If you paid or accrued foreign taxes to a foreign country on foreign source income and are subject to U.S. tax on the same income, you may be able to take these qualified foreign taxes as a tax credit to offset (in part or in full) your U.S. tax liability. An important questions arises for […]