Washington D.C. Tax Law Blog

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 […]

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 […]

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 […]

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 […]

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 […]

The Internal Revenue Service (IRS) has provided some guidance for small businesses. The agency recently posted a news release to remind small business owners of a tax credit that is available for those who hire long-term unemployment recipients. What is this tax credit? The Work Opportunity Tax Credit (WOTC) is available for qualified first and […]

Thinking of giving up United States citizenship? You may owe an exit tax. The exit tax, also known as the expatriation tax, is due in certain situations when a citizen of the United States renounces his or her citizenship. The government determines this tax obligation based on one of three tests. A failure of any […]

The Internal Revenue Service (IRS) recently announced the Offshore Voluntary Disclosure Program (OVDP) will end. The OVDP is currently scheduled to close on September 28, 2018. What is the OVDP? The program began in 2009. It provided an opportunity for those with offshore accounts to voluntarily come into compliance with United States tax laws. Those […]

The Internal Revenue Service (IRS) expects United States citizens and resident aliens to report certain foreign assets. Individuals with foreign assets generally fit one of two categories: either they live and work abroad or live stateside but have foreign financial interests. Tax obligations for those who live and work abroad It is important to report […]

The Supreme Court of the United States (SCOTUS) declined to hear a case that questions the constitutionality of the Foreign Account Tax Compliance Act (FATCA). A group of American expatriates brought the case against the government based on the contention that it violated their Fourth Amendment protections and the law has resulted in financial loss. […]