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 […]
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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 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 […]
The term “foreign financial accounts” is described expansively and includes any bank, brokerage, securities, securities derivatives and other financial instruments accounts located outside of the United States and its territories. In the instructions to the FinCEN Form 114 formerly Form TD F 90-22.1, the IRS also includes in this definition savings, demand, deposit, time deposit, […]
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 […]