The U.S. District Court for the Eastern District of Pennsylvania denied summary judgment to both the IRS and a taxpayer with regard to his Swiss bank account. In the case, the IRS slapped the maximum penalty on the taxpayer for willfully failing to file a Report of Foreign Bank and Financial Accounts (FBAR).
The Court concluded that whether the taxpayer willfully failed to submit an accurate FBAR was an inherently factual question and that genuine disputes existed as to what the taxpayer knew about his reporting requirements and when he knew it.
June 30th deadline for filing the Form 114 – Individuals Filing the Report of Foreign Bank and Financial Accounts has passed, but the IRS continues its fight to secure US tax revenue from foreign financial accounts. (more…)
IRS recently reminded all taxpayers about the June 30 deadline for Foreign Bank and Financial Accounts (FBAR) reporting. FBAR filings have risen dramatically in recent years as FATCA phases in and other international compliance efforts have raised awareness among taxpayers with offshore assets. According to data from FINCEN, FBAR filings exceeded 1 Million in calendar year 2014.
On September 30, 2013, Financial Crimes Enforcement Network (FinCEN), posted, a notice announcing FinCEN Form 114, Report of Foreign Bank and Financial Accounts (the current FBAR form). Form 114 supersedes, TD F 90-22.1 and has to be filed through BSA E-Filing System. This is the major change for 2014 tax year. Below is a recap of the requirements to file FBAR which has not changed from prior year.
These days, bitcoin has been a growing topic with my clients. Therefore, to wrap up our series on bitcoin blogs, Part I and Part II, I thought I would share my recent research for a client on the taxability of mining bitcoins and on their Report of Foreign Bank and Financial Accounts (FBAR) when they are held in a digital wallet.
Latest Offshore Voluntary Disclosure Initiative. Acknowledging that some overseas, delinquent taxpayers (including dual citizens) desire to become compliant, the IRS has announced an additional offshore voluntary disclosure initiative designed specifically for US nonresidents went into effect September 1, 2012. However, under the plan only individuals characterized as “low compliant risk” may generally file their past returns without penalties. Low compliant risk individuals are typically those with simple tax returns and who owe $1,500 or less in taxes. High compliant risk individuals are not eligible for the initiative, and may face late fees and penalties upon attempted participation. High compliance risk factors include…