IRS Cannot Assess 5471 Penalties Rules The Tax Court

April 3, 2023 (Washington D.C.) In a decision that is sure to be challenged by the IRS, the United States Tax Court (Farhy v Commissioner, 160 TC No.6, 3 April 2023) ruled  that “Congress has explicitly authorized assessment with respect to myriad penalty provisions in the Code, but not for [Form 5471 penalties].”  The Tax […]

High Court rules FBAR penalty is imposed per report, not per account

February 28, 2023 The U.S. Supreme Court held today in a 5-4 decision that the $10,000 penalty for a non-willful failure to file a Report of Foreign Bank and Financial Accounts (FBAR) for foreign accounts accrues per report, not per account (Bittner, No. 21-1195 (U.S. 2/28/23)). The decision resolves a split between the Fifth and Ninth […]

FinCen to Require Reports on Beneficial Ownership

Immediate Release March 24, 2023 WASHINGTON—Today, the Financial Crimes Enforcement Network (FinCEN) published its first set of guidance materials to aid the public, and in particular the small business community, in understanding upcoming beneficial ownership information (BOI) reporting requirements taking effect on January 1, 2024. The new regulations require many corporations, limited liability companies, and […]

Giving Up Your US Citizenship

IR-2019-151, September 6, 2019 WASHINGTON — The Internal Revenue Service today announced new procedures that will enable certain individuals who relinquished their U.S. citizenship to come into compliance with their U.S. tax and filing obligations and receive relief for back taxes. The Relief Procedures for Certain Former Citizens apply only to individuals who have not […]

Don’t Lose Your Passport

WASHINGTON — The Internal Revenue Service today urged taxpayers to resolve their significant tax debts to avoid putting their passports in jeopardy. They should contact the IRS now to avoid delays in their travel plans later. Under the Fixing America’s Surface Transportation (FAST) Act, the IRS notifies the State Department (State) of taxpayers certified as […]

Is Cryptocurrency Reportable on an FBAR?

Is Cryptocurrency Reportable on an FBAR? Many investors have made small fortunes in the virtual currency, aka cryptocurrency, markets. As this type of investment has become more mainstream, investors are now having to deal with tax compliance aspects of investing in cryptocurrency. This article addresses the FBAR reporting requirements for cryptocurrency. FBAR Implications of Cryptocurrency […]

IRS to End Offshore Voluntary Disclosure Program..Streamlined Program Next?

March 13, 2018 WASHINGTON – The Internal Revenue Service today announced it will begin to ramp down the 2014 Offshore Voluntary Disclosure Program (OVDP) and close the program on Sept. 28, 2018. By alerting taxpayers now, the IRS intends that any U.S. taxpayers with undisclosed foreign financial assets have time to use the OVDP before […]

Deutsche Bank to pay $95 million to resolve U.S. tax claims

(Bloomberg) Deutsche Bank AG agreed to pay $95 million to settle U.S. claims it used underfunded shell companies to evade taxes, the second time since 2010 that it resolved a government tax case. The U.S. sued the bank in 2014 after its 1999 purchase of a company that held stock whose sale would trigger more […]

Breaking: ICIJ publishes new leak of offshore corporate data

A cache of leaked documents provides names of politicians and others linked to more than 175,000 Bahamian companies registered between 1990 and 2016 For years, Neelie Kroes traveled Europe as one of the continent’s senior officials, warning big corporations that they couldn’t “run away” from the European Union’s rules. The Dutch politician sympathized with average citizens […]

Foreign Account Filings Top 1 Million; Taxpayers Need to Know Their Filing Requirements

WASHINGTON – Strong and sustained growth of taxpayers complying with foreign financial account reporting reflects improving awareness and compliance of this important part of offshore tax rules, the Internal Revenue Service said today. “Taxpayers here and abroad need to take their offshore tax and filing obligations seriously,” said IRS Commissioner John Koskinen. “Improving offshore compliance […]