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FinCEN › Reporting Requirements › Tax Planning

The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of... more +
The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of money laundering, terrorist financing and other financial crimes by collecting, monitoring, and analyzing financial transaction data. Such data is disseminated to both domestic and international law enforcement agencies. less -
Allen Barron, Inc.

US Taxpayers and Expatriates May Need to File Offshore Disclosures and FBARs

Allen Barron, Inc. on

How many U.S. taxpayers and expatriates may need to file offshore disclosures and FBARs with the IRS? Should those who have not yet filed a disclosure application utilize the VDP (Voluntary Disclosure Program) or a...more

Allen Barron, Inc.

Tax Developments for US Expatriates

Allen Barron, Inc. on

There have been many recent tax developments for U.S. expatriates. It is essential for U.S. citizens residing outside the United States and those considering an expat life to understand their responsibilities as U.S....more

Morrison & Foerster LLP

Treasury Department Shifts CTA to Foreign Entities

Morrison & Foerster LLP on

As we recently reported, the Financial Crimes Enforcement Network (FinCEN) has been chipping away at the CTA, including through a recent notice. Now, Treasury has dramatically changed the CTA landscape with respect to U.S....more

Allen Barron, Inc.

A Foreign Trust Creates Complex IRS Reporting Requirements

Allen Barron, Inc. on

The IRS has clearly identified legitimate reasons why "U.S. Persons" would establish or maintain ownership in a foreign trust. However, a foreign trust creates complex IRS reporting requirements for US taxpayers who own a...more

Allen Barron, Inc.

Foreign Corporate Ownership and Investments

Allen Barron, Inc. on

Are you involved in offshore or foreign corporate ownership and investments? Do you have real property, assets, or foreign bank or investment accounts? U.S. taxpayers with offshore business interests, holdings, investments,...more

PilieroMazza PLLC

Corporate Transparency Act, Part 2: Exempt Status, Physical Office, Dissolved and Tribal Entities, and Beneficial Ownership...

PilieroMazza PLLC on

The Corporate Transparency Act (CTA), which came into effect on January 1, 2024, has significant implications for government contractors, tribal entities, and commercial businesses. If you formed an entity before January 1,...more

Allen Barron, Inc.

US Expatriate Tax Planning - Part 1 - A Podcast with Janathan Allen

Allen Barron, Inc. on

In the US Expatriate Tax Planning podcast, Janathan Allen discusses important tax issues from the perspective of a US Expatriate. One of the first and most important thing to know for any US taxpayer is the United States...more

Falcon Rappaport & Berkman LLP

Digital Assets Reporting Requirements Under Section 6050I

Falcon Rappaport & Berkman LLP on

On January 16, 2024, the Treasury Department and Internal Revenue Service (“IRS”) announced that the agencies are postponing the implementation of increased reporting requirements for digital asset transactions under the...more

Arnall Golden Gregory LLP

2024 Brings Estate Planning Opportunities, Significant Reporting Obligations

Arnall Golden Gregory LLP on

Wealthy families should consider taking advantage of the favorable estate planning environment that 2024 brings. Next year, the estate, gift, and generation-skipping transfer tax exemptions, which are adjusted annually for...more

Freeman Law

IRS Issues Guidance on FBAR: LB&I FBAR Practice Unit

Freeman Law on

The Bank Secrecy Act (“BSA”) requires United States persons (“USPs”) to file FinCEN Forms 114, Report of Foreign Bank and Financial Accounts (“FBARs”), for each calendar year in which the aggregate amount(s) in certain...more

Freeman Law

Flint Demonstrates the Risks in Trying to Make a Willful IRS Streamlined Filing Non-Willful

Freeman Law on

Federal case and after federal case continues to come out providing real-life examples of the pitfalls of filing a Streamlined Filing Compliance Procedure (“SFCP”) with the IRS when the facts suggest willfulness rather than...more

Freeman Law

IRS Issues FBAR Reference Guide

Freeman Law on

The IRS and FBARs - On March 30, 2022, the IRS issued Publication 5569, Report of Foreign Bank & Financial Accounts (FBAR) Reference Guide. The 12-page publication provides helpful information to both taxpayers and tax...more

Foodman CPAs & Advisors

How Will Virtual Currency Be Taxed?

Foodman CPAs & Advisors on

Despite the confusing interpretations by US regulators, non-compliance with crypto tax rules can cost taxpayers dearly. Unfortunately, the answer to “how is virtual currency taxed” depends on who you ask....more

Foodman CPAs & Advisors

Upcoming Virtual Currency FBAR and FATCA Reporting Enforcement

Foodman CPAs & Advisors on

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

Freeman Law

Death Doesn’t Stop the IRS—Failure to File FBARs

Freeman Law on

Benjamin Franklin once famously wrote in a 1789 letter, “In this world nothing can be said to be certain, except death and taxes.” Many recognize the truth in Mr. Franklin’s statement. Some may also believe that certain death...more

Foodman CPAs & Advisors

FBAR Penalties: Is it per Account or per Violation?

Foodman CPAs & Advisors on

U.S. Taxpayers (includes a citizen, permanent resident, corporation, partnership, limited liability company, trust and estate) are required to file a Report of Foreign Bank and Financial Accounts (FBAR) if they have...more

McDermott Will & Schulte

Weekly IRS Roundup December 23 – 27, 2019

McDermott Will & Schulte on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 23 – 27, 2019. December 20, 2019: The Department of the Treasury’s Financial Crimes...more

Holland & Knight LLP

Virtual Currency: The Taxman is Coming

Holland & Knight LLP on

Virtual currency transactions are now a prime focus of Internal Revenue Service (IRS) scrutiny. The IRS has numerous information-gathering tools to enforce its taxing power, including summons, artificial intelligence, data...more

Foodman CPAs & Advisors

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

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

Jones Day

Blockchain and Tax: Navigating Uncertainty

Jones Day on

Virtual currencies (often called cryptocurrencies) such as bitcoin are perhaps blockchain's best-known application. As these and other blockchain-based digital assets become more common, and attract more regulatory and...more

Foodman CPAs & Advisors

Residential Real Property Purchased with Virtual Currency must be Reported

Foodman CPAs & Advisors on

On November 15, 2018, the Financial Crimes Enforcement Network (FinCEN) announced the issuance of a “Revised” Geographic Targeting Order (GTO) that requires U.S. title insurance companies (Covered Business) to identify the...more

Orrick, Herrington & Sutcliffe LLP

IRS Outlines New Process for Voluntary Disclosures

Orrick, Herrington & Sutcliffe LLP on

On November 29, 2018, the Internal Revenue Service (the "IRS") published a memorandum (the "Memorandum") dated November 20, 2018, outlining the new process for all voluntary disclosures, both domestic and offshore (the "New...more

Foodman CPAs & Advisors

Did you know that GTO’s have a $300,000 Threshold?

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A GTO is a Geographic Targeting Order issued by the Financial Crimes Enforcement Network (FinCEN) under the Bank secrecy Act (BSA) for a specific geographic area. ...more

Orrick, Herrington & Sutcliffe LLP

IRS To Terminate The Offshore Voluntary Disclosure Program

Orrick, Herrington & Sutcliffe LLP on

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

Foodman CPAs & Advisors

FBARs 101

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US Taxpayers (which includes US Citizens, Permanent Residents, Trusts, Estates, and Domestic Entities) with an interest in foreign financial accounts that meet the reporting threshold of an aggregate value exceeding $10,000...more

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