Getting Into Compliance with Your Foreign Account Reporting, Part I

Other Posts in this Series Part II Part III With the 2015 release of the “Panama Papers,” roughly 11.5 million documents detailing personal financial information of wealthy individuals and identifying nearly 215,000 offshore entities are now available to government authorities. That and other leaks, as well as the overall step-up...

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...

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...

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...