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On September 14, 2012, the U.S. Department of the Treasury announced that it has signed a bilateral agreement with the United Kingdom to implement the information reporting and withholding tax provisions commonly known as the Foreign Account Tax Compliance Act (FATCA). Enacted by Congress in 2010, these provisions target non-compliance by U.S. taxpayers using foreign […]
This year, the usual September deadline for estimated tax payments for the the third-quarter (June 1-August 31) of 2012 moves to September 17 due to the fact that the usual date for the estimated tax payments (September 15) falls on Saturday. This requirements applies individuals who are either not paying their income tax through withholding […]
If your client’s offshore voluntary disclosure involves PFIC (Passive Foreign Investment Company) income, you should be aware that the 2012 OVDP now closed (Offshore Voluntary Disclosure Program) offers an alternative PFIC calculation method. In this article, I intend to outline broad contours of the alternative method and put it in a broader context of voluntary […]
Potentially, a person who willfully fails to file an FBAR or files a false FBAR may be subject to: A prison term of up to 10 years Criminal penalties of up to $500,000 or both When it comes to penalties, FinCEN Form 114 formerly Form TD F 90-22.1, Report on Foreign Bank and Financial Accounts […]
Failure to do timely voluntary disclosure may expose non-compliant U.S. taxpayers with foreign bank and financial accounts to tremendous amount of audit penalties. In this article, I will describe these penalties which may apply to non-compliant U.S. taxpayers during an IRS audit (remember, the application of these penalties in your particular case will depend on […]