| 
The FBAR and FATCA obligations with respect to French bank accounts are extensive and can often be quite burdensome for US owners of these accounts. This is one of the main reasons why France has been consistently one of the top sources of clients for my firm with respect to offshore voluntary disclosures. In this […]
Despite the surge in FATCA letters from Spanish banks in the past two years, there is a significant number of US taxpayers with Spanish bank accounts who still have not complied with their US tax obligations. In this essay, I would like to discuss the most common US tax reporting requirements of individual US owners […]
Despite the domination of international tax compliance by FATCA since at least July of 2014, many US owners of Lebanese bank accounts are still not compliant with their US tax obligations. In fact, for many of them, the receipt of a FATCA letter is a huge surprise. In this essay, I would like to discuss […]
There has been virtually no discussion of the impact of the OVDP closure beyond how it affects the ability of willful taxpayers to settle their past noncompliance. This is very unfortunate, because there is a direct correlation between OVDP and IRS tax enforcement activities. In this article, I will discuss how the OVPD closure sets […]
One of the most important considerations in an offshore voluntary disclosure is the type of assets that form the Penalty Base for the imposition of the Miscellaneous Offshore Penalty. In this article, I would like to explore the issue of whether there is such a thing as SDOP Real Estate Penalty. SDOP Real Estate Penalty: […]