FATCA, FinCEN | JD Supra

International Business and Offshore Investment and Banking Create Genuine IRS Risk

Allen Barron, Inc. on 2/19/2025

International business and offshore investment and banking create genuine risk and exposure with the IRS. This extends to real estate ownership outside of the U.S. and other offshore-related financial activities, which raise...more

NTA Addresses Overlap Reporting

Foodman CPAs & Advisors on 1/28/2025

On 1/8/25, the National Taxpayer Advocate (NTA) published its 2024 Annual Report to Congress and identified taxpayers’ problems and provided suggestions to further protect taxpayer rights and ease taxpayer burden. “By law,...more

GLI British Virgin Islands blockchain and cryptocurrency regulation 2025, seventh edition

Carey Olsen on 1/8/2025

Regulatory clarity in the digital assets and crypto space continues to be a moving target. Yet, the interest among policymakers and regulators worldwide has never been more pronounced. In the United States, 2024 was a pivotal...more

Taxpayers Abroad are Underserved and Challenged

Foodman CPAs & Advisors on 9/6/2024

The National Taxpayer Advocate 2023 Annual Report to Congress highlights how Taxpayers abroad are underserved and continue to face challenges in meeting their U.S. tax obligations. As a result, the National Taxpayer Advocate...more

How Does the IRS Use AI to Identify Tax Cheats?

Allen Barron, Inc. on 12/13/2023

Could Artificial Intelligence (AI) increase the likelihood of an IRS audit in your future? How does the IRS use AI to identify US taxpayers who attempt to hide assets, under-report income or otherwise cheat the IRS? In...more

Are There Strategies to Avoid an IRS Audit?

Allen Barron, Inc. on 11/28/2023

Are there strategies to avoid an IRS audit? What are some of the known risks for triggering an IRS audit? What should you do if you have are concerned about the information provided a previous tax return? Is there a way to...more

An International Tax Primer for US Taxpayers and Expatriates – Part 1 of 2

Allen Barron, Inc. on 8/24/2023

Welcome to part 1 of our Allen Barron International Tax Primer for US Taxpayers and Expatriates. The United States is one of the few countries in the world that taxes its citizens on their worldwide income. US taxpayers are...more

¿Cuándo Son Los Casinos Instituciones Financieras?

Foodman CPAs & Advisors on 1/10/2023

De acuerdo con el IRS y FinCEN, los casinos con licencia para hacer negocios como casinos y que tienen ingresos brutos anuales de juego superiores a $1,000,000 son instituciones financieras sujetas a los requisitos de la Ley...more

Upcoming Virtual Currency FBAR and FATCA Reporting Enforcement

Foodman CPAs & Advisors on 7/8/2021

Under current FinCEN regulations, a foreign account holding virtual currency is not reportable on the FBAR. However, FinCEN in its FinCEN Notice 2020-2, proposes amending reports of foreign financial accounts (FBAR)...more

Financial Institutions Can No Longer Afford to Underfund Compliance Hiring and Training

Foodman CPAs & Advisors on 6/18/2020

The Covid-19 Pandemic and the accompanying reduction in economic activity has been a rationale for Financial Institutions (FI) to re-analyze their budgets for compliance training and education. FIs, as well as businesses in...more

Taxpayers that have VIRTUAL CURRENCY held in a Centralized Virtual Currency Exchange outside the U.S must file an FBAR and FORM...

Foodman CPAs & Advisors on 6/10/2019

On May 30, 2018, the AICPA (American Institute of Certified Public Accountants) wrote a letter to the IRS to obtain further definition and clarity regarding Virtual Currency (VC) FATCA and FBAR reporting requirements....more

Malta Mambo - Using Malta Pension Plans as An Alternative to the Charitable Remainder Trust

Gerald Nowotny - Law Office of Gerald R.... on 9/21/2018

In the early 1990’s while attending the University of Miami School of Law, aka Harvard of the South, I worked in the Miami Agency of the National Life of Vermont (NLV). The Company always had a strong propensity towards...more

The Perils Facing a U.S. Person Having an Undeclared Offshore Financial Account

Baker Donelson on 8/10/2018

There are legal and financial consequences to any U.S. person who underreports their income. Moreover, similar consequences may exist even in a situation in which all income is reported, yet certain information returns are...more

IRS To Terminate The Offshore Voluntary Disclosure Program

Orrick, Herrington & Sutcliffe LLP on 3/23/2018

On March 13th, the Internal Revenue Service ("IRS") announced that the offshore voluntary disclosure program ("OVDP"), which was first launched in 2009 and modified several times, will close to new taxpayers after September...more

Annual Compliance Obligation Reminders

Vedder Price on 2/16/2018

Investment advisers registered with the U.S. Securities and Exchange Commission (“SEC”) or with a state (“Advisers”) as well as commodity pool operators (“CPOs”) and commodity trading advisors (“CTAs”) registered with the...more

Income, from Whatever Exchange, Mine, or Fork Derived: The Basics of U.S. Cryptocurrency Taxation

Proskauer - Tax Talks on 12/7/2017

In this first of (we hope) many posts on the interesting and myriad tax issues arising in the world of cryptocurrency and blockchain technology, we focus on the very basic U.S. federal income tax consequences of...more

New Due Date for “FBAR” Filings - Report of Foreign Bank and Financial Accounts now due on Tax Day, with auto-extension for six...

Pillsbury Winthrop Shaw Pittman LLP on 4/18/2017

Federal law requires U.S. citizens and resident aliens to report world-wide income, including income from foreign trusts, bank and securities accounts. In addition to attaching Schedule B to their tax returns disclosing...more

New Extended Due Dates for Foreign Bank Account Reports (FBAR)

Burr & Forman on 1/30/2017

All U.S. citizens and permanent residents are required to annually file a U.S. income tax return reporting their worldwide income from all sources. Additionally, U.S. citizens and permanent who have an interest in or...more

Panama Papers Fallout: A Push for Transparency and Regulatory Reform - Sanctions Also Levied Against Several Panama-Based...

Holland & Knight LLP on 5/20/2016

In the wake of the "Panama Papers" – the unprecedented leak of 11.5 million files from a Panamanian law firm that revealed thousands of names and addresses linked to offshore companies – the White House has announced several...more

Foreign Account Tax Compliance Act › FinCEN