Streamlined Foreign Offshore Procedures
The streamlined foreign offshore procedures (SFOP) are part of the streamlined filing compliance procedures. Unlike the streamlined domestic offshore procedures, there is no 5% misc. offshore …
Streamlined Domestic Offshore Procedures
Contents1 Streamlined Domestic Offshore Procedures – Overview2 Eligibility for the streamlined domestic offshore procedures2.1 Non-willfulness3 Disqualification from the streamlined domestic offshore procedures4 Title 26 miscellaneous …
Delinquent International Information Return Submission Procedures
Many Taxpayers have filed under the delinquent international information return submission procedures (DSP). Contents1 What are the Delinquent International Information Return Submission Procedures?1.1 Changes after …
Ninth Circuit Holds that Non-Willful FBAR penalty is Assessed Per Form
Following a string of other similar decisions, the Ninth Court Court of Appeals in United States v. Boyd finds that the non-willful FBAR penalty is …
New IRS Campaign Targets Nonresident Rental Income
The IRS recently announced an LB&I campaign that targets nonresidents who own U.S. rental properties. Based on past experience, IRS campaigns should be taken seriously. …
IRS Announces Section 965 Compliance Campaign
This week the IRS announced a new Section 965 compliance campaign in it’s LB&I division. While U.S. corporations have owed the vast majority Section 965 …
New Exemptions & Penalty Relief for Form 3520 and 3520-A
In early March 2020, the IRS released Rev. Proc. 2020-17 which provides an exemption from the information reporting requirements under IRC § 6048 – specifically, …
FIRPTA Withholding Requirements
The disposition of a U.S. real property interest by a foreign seller (the transferor) is subject to the Foreign Investment in Real Property Tax Act …
Form 8938 Filing Requirements
“FATCA” (Foreign Account Tax Compliance Act) requires specified individuals to report ownership of specified foreign financial assets if the total value exceeds the applicable reporting …
Foreign Bank Account Reporting under the Bank Secrecy Act (FBARs)
If you are a US citizen or tax resident, you may have a foreign bank account reporting obligation. There are individuals who don’t report their …
FBAR Civil Penalty Cases
FBAR penalties are assessed for both willful and non-willful violations. Penalties for willful violations carry significantly larger penalties. For clients wishing to correct past non-compliance, …