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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 penalty assessed on a streamlined foreign offshore procedures filing. U.S. taxpayers eligible to use these procedures will file delinquent or amended returns, together with all required international information returns (Forms … Read more

Foreign Accounts Compliance and Statute of Limitations

IRC § 6038D, enacted on Mar. 18, 2010, and effective for taxable years beginning after the date of enactment, imposes reporting requirements with respect to certain “specified foreign financial assets”. The requirements are satisfied by an accurately filed Form 8938. Form 8938, Statement of Foreign Financial Assets, is required to be filed by specified individuals who … Read more

Reporting of Foreign Assets

Individuals with foreign assets or interests may have one or more of the following reporting requirements: FinCEN Form 114, also known as FBAR Foreign Bank and Financial Accounts Reporting (FBAR). All US persons (which include US Citizens and resident aliens) who have a financial interest or signatory authority over foreign accounts which have an aggregate value of … Read more

Delinquent International Information Return Submission Procedures

Since the 2014 OVDP changes some taxpayers with unreported income from unreported foreign assets have filed under the Delinquent International Information Return Submission Procedures. Contents1 What are the Delinquent International Information Return Submission Procedures?1.1 Can I use this program if I also have unreported income from foreign assets?1.2 What are the requirements to file under … Read more

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 offshore penalty4.1 Determine the penalty base4.2 Financial interest: beneficial interest and legal interest4.3 Co-owners4.4 Are previously reported accounts included in the penalty base?4.5 Determine the penalty amount5 General treatment under … Read more

IRS Begins Sending Letters to Cryptocurrency Owners

The IRS has started sending letters to taxpayers with currency transactions and who potentially failed to report income and pay tax resulting from the virtual currency transaction or did not report their transactions property. The IRS began sending these letters last week and expects that more than 10,000 taxpayers will receive such letters. Contents1 Who’ll … Read more

Zurich Life Insurance Company Hit with Penalties for Unit-Linked Life Insurance Policies

From DOJ press release, excerpts below: Zurich Life Insurance Company Ltd (Zurich Life), headquartered in Zurich, Switzerland, and Zurich International Life Limited (Zurich International Life), headquartered in the Isle of Man (collectively Zurich) reached a resolution with the United States Department of Justice…As part of the agreement, Zurich will pay a penalty of $5,115,000 to … Read more