News & Analysis as of

Offshore Funds Filing Requirements

Conyers

Economic Substance Declaration Filings – May 2025

Conyers on

The Economic Substance Act 2018 (the “Act”) requires Bermuda-based entities that are carrying on a “relevant activity” in a relevant financial period and entities claiming “non-resident entity” status under the Act to file an...more

Allen Barron, Inc.

Offshore Real Estate Ownership and Tax Reporting Requirements

Allen Barron, Inc. on

What do you need to know about offshore real estate ownership and any associated tax reporting requirements? Are you a U.S. taxpayer or U.S. resident who owns real estate outside of the United States? It may surprise you to...more

Allen Barron, Inc.

IRS Revisions to the Voluntary Disclosure Program for 2024

Allen Barron, Inc. on

What are the IRS revisions to the Voluntary Disclosure Program for 2024? The foundation of the current IRS Voluntary Disclosure Program (VDP) goes as far back as 2009 when the agency worked to provide U.S. taxpayers with a...more

Allen Barron, Inc.

IRS Updated Streamlined Filing Compliance Procedures

Allen Barron, Inc. on

What do you need to know about the IRS updated Streamlined Filing Compliance Procedures or "Streamlined Procedures?" Are you concerned about unreported or under-reported offshore income or assets? Are there accounts you...more

Allen Barron, Inc.

Questions Regarding Offshore Accounts and FBAR Filing Requirements

Allen Barron, Inc. on

Many US taxpayers still have questions regarding offshore accounts and FBAR filing requirements and compliance. Is there a genuine risk their activities (or lack of compliance) will come to light? The definition of a US...more

BakerHostetler

Per-Account or Per-Form Penalty?

BakerHostetler on

Key Takeaways: ..The law regarding computation of FBAR penalties is unclear. ..The United States Supreme Court has agreed to hear a case to settle a conflict among the circuit courts. ..Until the Supreme Court...more

Freeman Law

Common Mistakes in Submitting an IRS Streamlined Filing Compliance Procedure Submission: And a Discussion of Professional...

Freeman Law on

For one reason or another, I had several calls last year with attorneys and others regarding IRS Streamlined Filing Compliance Procedure submissions gone wrong. In most cases, it was evident that the tax professional had...more

Foodman CPAs & Advisors

El IRS Está En Una Misión De Reducir La Brecha Fiscal

La diferencia entre el monto del impuesto adeudado por los Contribuyentes para un año determinado y el monto que realmente se paga oportunamente para ese mismo año se conoce como “Brecha Fiscal Bruta” (“Tax Gap”). El IRS...more

Foodman CPAs & Advisors

Closing A Foreign Bank Account Will Not Solve A Taxpayer’s Disclosure Problem

IRS is interested in U.S. Taxpayer financial accounts everywhere in the world.  If the IRS learns that a Taxpayer has undisclosed reportable accounts or income before a US Taxpayer reports them, the Taxpayer can face serious...more

Lowndes

Don’t Forget to File Your Foreign Bank Account Return

Lowndes on

If you have a foreign bank account (or signatory authority on a foreign bank account), you are required to file a Form 114 (commonly called an FBAR) if at any point during the calendar year the combined balance in all of your...more

Foodman CPAs & Advisors

IRS: Las Cuentas Financieras “Offshore” NO pasarán Inadvertidas

El 15 de marzo del 2019, el IRS informó que la ocultación de dinero o activos en cuentas extraterritoriales (“offshore”) no declaradas permanece en la lista de las estafas tributarias conocidas come la Docena Sucia o "Dirty...more

Foodman CPAs & Advisors

IRS: Offshore Financial Accounts will NOT go Unnoticed

On March 15, 2019, IRS reported that hiding money or assets in unreported offshore accounts remains on the Internal Revenue Service’s “Dirty Dozen” list of tax scams for 2019....more

Snell & Wilmer

IRS Amends Program for Offshore Voluntary Disclosures

Snell & Wilmer on

On September 28, 2018, the Internal Revenue Service (IRS) ended its 2014 Offshore Voluntary Disclosure Program (OVDP). The 2014 OVDP (which was an extension of the 2009 and 2011 OVDPs) was meant to allow taxpayers who...more

Foodman CPAs & Advisors

Streamlined Filing Program for U.S. Taxpayers Residing Outside of the U.S. continues to be available but can be Discontinued at...

After the closing of the Offshore Voluntary Disclosure Program (OVDP) - which ended on September 28, 2018, the US Department of Treasury released a Memorandum on November 20, 2018, disclosing an “Updated Voluntary Disclosure...more

Butler Snow LLP

5 Common Tax Misconceptions Facing U.S. Persons Living Outside the U.S.

Butler Snow LLP on

Living abroad can be a wonderful opportunity for many U.S. Persons, but a few commonly misunderstood aspects of the U.S. tax system directly impact such “expats,” often to their financial detriment. Here are the five most...more

Burr & Forman

IRS Announces End to Foreign Bank Account Disclosure Program: What Can You Do Now If You Still Have Unreported Foreign Bank...

Burr & Forman on

The IRS recently announced it will be shutting down its successful Offshore Voluntary Disclosure Program (OVDP) for unreported foreign bank accounts and income. The program will end September 28, 2018. Under the OVDP, first...more

Pillsbury Winthrop Shaw Pittman LLP

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

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

Lowndes

Tax Day Has Passed, But Don’t Forget June 30th!

Lowndes on

Now that April 15th has passed, you might be thinking that you are done with tax filings for the year. But, if you have any foreign bank accounts or financial assets overseas, you may be required to file a Form 114 (commonly...more

Blank Rome LLP

IRS Clarifies Requirements for Streamlined Filing Procedures

Blank Rome LLP on

On October 9, 2014, the Internal Revenue Service published additional guidance clarifying the requirements for participation in the Streamlined Filing Compliance Procedures. (See prior coverage of the new procedures...more

Eversheds Sutherland (US) LLP

What Financial Advisers and Accountants Should Know About Expanded IRS Streamlined Filing Compliance Procedures for U.S. Taxpayers...

The Internal Revenue Service (IRS) recently announced “major changes” to its offshore compliance programs, including the Streamlined Filing Compliance Procedures (Streamlined Procedures), the delinquent international...more

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