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 …
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 …
Delinquent international information return submission procedures (DSP) were one of the four methods for taxpayers with unreported offshore accounts to become compliant. Contents1 What are …
If you’re a U.S. taxpayer with investments in foreign mutual funds, offshore companies, or overseas ETFs, you may unknowingly own a Passive Foreign Investment Company …
Here some common mistakes we have come across by FBAR filers. Contents1 #1 Not reporting non-bank financial accounts1.1 What is a financial account?2 #2 Filing …
Classifying foreign pension plans for U.S. tax reporting can be confusing and contain many pitfalls. Further complicating matters is that other countries consider their plans …
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 …
In at least the second such instance that we’re aware of, the Government has brought charges related to filing a false streamlined submission, among other …
After a district court in Texas recently held that penalties for the non-willful failure to file an FBAR is be assessed by form (and not …
The IRS Small Business & Self-Employed Division updated guidance (SBSE-04-1120-0074) for foreign bank account report compliance activity due to the COVID-19 pandemic. A text of …
In a recent case before the U.S. Court of Federal Claims, two married taxpayers appeared pro se in challenging the assessment of passive foreign investment …
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. …