Can the IRS Enforce the FATCA?
The Foreign Account Tax Compliance Act (FATCA) requires foreign financial institutions to register with the Internal Revenue Service (IRS) and report the holdings of United States taxpayers. Foreign institutions that fail to abide by this law face serious monetary consequences — up to 30 percent of the income received from U.S. sources. But is the […]
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Reminder: Get Foreign Accounts in Order Before OVDP Sunsets
The Internal Revenue Service (IRS) recently announced the impending end of the Offshore Voluntary Disclosure Program (OVDP). The program, scheduled to end this September, offers a trade. In exchange for reporting previously undisclosed foreign assets, the IRS will cap some of the potential penalties. The IRS also notes that participation in the OVDP reduces the […]
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IRS Recommends “Paycheck Checkup” to Adjust Tax Obligations
Considering recent tax law changes, the Internal Revenue Service (IRS) encourages taxpayers to conduct a “paycheck checkup” and adjust tax obligations accordingly. What is a paycheck checkup? This term refers to a review of one’s paycheck to check and adjust the withholding status as needed. Why do I need to review this information? The Tax […]
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SCOTUS Rules in Favor of Online Tax — What’s Next for Businesses?
The Supreme Court of the United States (SCOTUS) agreed to allow states to impose a tax on online transactions in the recent case South Dakota v. Wayfair. Why is the ruling important? In order to move forward with this change, SCOTUS had to overturn two previous decisions, one in 1967 and one in 1992. These […]
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The Price of Paradise: Taxes and Foreign Property
The allure of a foreign country calls to many United States citizens. Some fall in love with the views, the culture, the weather. Some choose to make their vacation destinations more than just an occasional stop, but rather invest in property and visit their personal paradise on a more regular basis. Ownership of property in […]
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Recent Case Questions Limit on FBAR Penalties
The Internal Revenue Service (IRS) requires those who hold an interest in or signature authority over a foreign account with a value over $10,000 at any point during the applicable tax year file the Foreign Bank Account Report (FBAR). A failure to do so can lead to both civil and criminal penalties. But how harsh […]
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What Happens if you Didn’t Pay the Transition Tax Under 965(e)?
The Internal Revenue Service (IRS) recently provided guidance on the application of section 965(e) of the Code. This section applies specifically to those who receive income from “certain specified foreign corporations.” The law basically requires a transition tax on foreign earnings. Who must pay this tax? The IRS requires United States shareholders as well as […]
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IRS Scores Big Win in Battle Against Facebook
The Internal Revenue Service (IRS) is taking on Facebook. The agency has accused Facebook of failing to report and pay taxes on billions of dollars of overseas income. The agency conducted an audit on the social platform in 2011. The audit focused on alleged financial discrepancies between 2008 and 2009. Eventually, the agency expanded the […]
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Court Provides Clarity on Standard of Proof in FBAR Dispute
The United States of America filed suit against a taxpayer for his alleged “willful” violation of the requirement to report an interest in a foreign account. The government had already established the taxpayer was required to file a Report of Foreign Bank and Financial Accounts (FBAR). The court is asked to determine which standard of […]
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5 face Criminal Charges for FATCA Violations
The Department of Justice recently indicted five individuals for obstruction of the Internal Revenue Service’s (IRS) administration of the Foreign Account Tax Compliance Act (FATCA). These individuals allegedly agreed to open offshore accounts without collecting required FATCA information. The agency accuses these individuals of scheming to evade reporting requirements. As noted in a recent press […]
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