Streamlined Domestic Offshore Procedures (SDOP)
The IRS Streamlined Domestic Offshore Procedures (SDOP) offer U.S. residents a way to come into compliance with foreign financial reporting requirements with significantly reduced penalties, …
Streamlined Foreign Offshore Procedures
The IRS Streamlined Foreign Offshore Procedures (SFOP) are the most generous offshore compliance program the IRS has ever offered. For eligible U.S. taxpayers living abroad, …
Delinquent International Information Return Submission Procedures
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 …
Why You Received a FATCA Letter — and What to Do About It
FATCA (Foreign Account Tax Compliance Act) is a U.S. tax law that requires foreign financial institutions to report accounts held by U.S. persons to the …
PFICs: A Costly Trap for U.S. Taxpayers with Foreign Investments
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 …
Top 5 FBAR Mistakes
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 …
Foreign Pension Plans Under 402(b)
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 …
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 …
Virginia Man is Charged with Filing False Streamlined Filing
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 …
District Court Says Only One FBAR Penalty Per Form
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 …
IRS Issues Temporary Guidance for FBAR Compliance Enforecement
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 …
Taxpayers challenge IRS’s Assessment of PFIC Taxes
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 …