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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, …

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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 …

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2017 FATCA Updates

2017 FATCA News

Foreign Account Tax Compliance Act (FATCA) was enacted in 2010 by Congress to target non-compliance by U.S. taxpayers with foreign accounts. FATCA requires foreign financial institutions (FFIs) to report to the IRS information about financial accounts held by U.S. taxpayers in which U.S. taxpayers hold a substantial ownership interest. FFIs are encouraged to either directly register with the IRS to comply with the FATCA regulations (and FFI agreement, if applicable) or comply with the FATCA Intergovernmental Agreements (IGA) treated as in effect in their jurisdictions.

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