Entries by Manager

FBAR: Financial Interest, Signature Authority, and Other Comparable Authority

One of the major requirements that gives rise to the obligation to file the FBAR is that a U.S. person has either a financial interest in, or a signature authority or other comparable authority over the relevant foreign financial accounts. In deciding whether the FBAR is required, it is useful to go through all three […]

FBAR Penalties

In this essay, I would like to discuss some of the penalties that may be imposed as a result of the failure to file the FBAR even though you were required to do so. In particular, I will focus on three general scenarios describing specific penalties commonly attributed to each of them. The first scenario […]

FBAR: Aggregate Value Requirement

FBAR filing is required only if the aggregate balances of a U.S. person’s foreign financial accounts exceed $10,000. Despite appearances, the requirement that the aggregate value of all of the foreign financial accounts exceeds $10,000 at any time during a calendar year is not without complications. In order to figure out the account value in […]

IRS Interest Rates: 4th Quarter of 2010

On August 19, 2010, the IRS announced that interest rates for the calendar quarter beginning October 1, 2010, will remain the same as follows: 1. Individual underpayment and overpayment: 4%; 2. Corporate overpayment: 3% 3. Large corporate underpayment: 6% 4. Portion of corporate overpayment exceeding $10,000: 1.5% The interest rate is determined on a quarterly […]