Filing Requirements for Overseas Business Investments

Failing to take IRS reporting requirements into consideration is among the biggest mistakes made by U.S. citizens when investing abroad. In addition to FinCEN 114 (the FBAR), U.S. Citizens with a certain percentage ownership in foreign corporations have several filing obligations with steep fines for noncompliance. These filing obligations include...

The Administrative Procedure Act – Challenging FBAR Penalties

Other Posts in this Series Background of Administrative Procedure Act Rulemaking Requirements Under the APA Adjudication and Licensing Judicial Review Over the past 10 years, thousands of U.S. taxpayers with a wide variety of circumstances have been forced to pay extraordinarily high penalties for failure to disclose foreign bank accounts....

IRS Agrees to Increased Enforcement of IRS’s Offshore Voluntary Disclosure Program

Both Prior Submissions and Future Submissions Effected (Announced by Government June 21, 2016) Treasury Inspector General's Report Issued to Internal Revenue Service Criminal Division and International Division In a report issued to the Internal Revenue Service International Division and Criminal Division, the Treasury Inspector General for Tax Administration (TIGTA) found...

Contesting tax and reporting return penalties: The FBAR, Part I: Penalties and Waiver

In an attempt to fight money laundering in the U.S., Congress passed the Bank Secrecy Act in 1970. Among the Act's requirements was the filing of FinCEN Form 114 (formerly Treasury Department Form 90-22.1) Report of Foreign Bank and Financial Accounts (FBAR). For many decades, compliance was low. This changed...

Subpart F: Taxation of Foreign Income Earned by U.S.-Controlled Foreign Corporations

In 2012, Google made headlines when it was revealed that the multinational company had avoided approximately $2 billion in worldwide income taxes the previous year by funneling the equivalent of 80% of the company's pre-tax profit through a Bermuda shell company. The tax avoidance techniques used by the company (the...

Taxation of Convertible Virtual Currency, Part I: It’s Not Money

Other Posts in this Series Part II: Taxation of Virtual Currency Income Part III: Reporting and Penalties for Noncompliance Ecuador will soon be the first country in the world to have digital currency issued by a central bank. Although the new Ecuadorian currency won’t necessarily function like Bitcoin, Litcoin, Peercoin...