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Tax Law Roundup current law developments in U.S. taxation

Category Archives: FBAR

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New Option for Late FBARs – Just File It!

Posted in Compliance, FBAR, International

An often overlooked filing obligation is the annual June 30 requirement to file the FBAR form for taxpayers with foreign bank accounts aggregating over $10,000. Late FBARs are a consistent problem and the IRS has a long history of complicated solutions. The latest (and greatest) is the “just file it!” approach, as long as the… Continue Reading

IRS Issues Internal FBAR Penalty Guidance To Ensure Consistency

Posted in FBAR, International

Shortly before the annual June 30 FBAR filing deadline, the IRS issued penalty guidance for those that miss the foreign bank account reporting deadline. The purpose of the new penalty guidance is to improve the IRS’s administration and application of FBAR penalties. The guidance is immediately effective for all open cases. The IRS observes that… Continue Reading

IRS Publishes Streamlined FBAR Compliance Procedures for Certain Non-Residents

Posted in FBAR, International

As promised, the IRS issued new instructions on streamlined procedures for certain low-risk non-residents to file late FBAR and income tax forms.  The applicability of these procedures is very limited and applies only to taxpayers who: (1)    are non-resident U.S. taxpayers who have resided outside of the U.S. since January 1, 2009 (2)    have not… Continue Reading

IRS Announces Third Late FBAR Amnesty Program

Posted in FBAR, International

It’s tax deja vu with yet another IRS amnesty program for persons filing late disclosures of offshore financial accounts, commonly referred to as FBAR (Foreign Bank Account Reporting).  The IRS announced that the new program generally resembles the 2009 and 2011 programs, except that there is no explicit ending date to the new program and the special amnesty penalty… Continue Reading

Latest FBAR Guidance – Limited Filing Extension

Posted in FBAR, International

The IRS has again updated its guidance on their latest voluntary disclosure program for late FBAR filings for foreign accounts over $10,000. Specifically, certain persons having signature authority over, but no financial interest in, a foreign financial account in 2009 or earlier calendar years now have until November 1, 2011 to file those FBARs. This… Continue Reading

Latest FBAR Guidance – Extensions and Opting Out

Posted in FBAR

The IRS updated its guidance on their latest voluntary disclosure program for late FBAR filings for foreign accounts over $10,000. Significantly, the guidance includes the ability to request a 90-day extension of the August 31, 2011 deadline if the taxpayer can demonstrate a good faith attempt to fully comply with FAQ 25 on or before… Continue Reading

IRS Updates Procedures for Determining Stock Basis

Posted in FBAR, General

In Rev. Proc. 2011-35, the IRS updated the procedures for determining IRS updated the procedures for determining stick bases when a corporation acquires the stock of another corporation in a transferred basis transaction. The revenue procedure adopts the surveying and statistical sampling guidelines in Rev. Proc. 81-70, but updates and revises them to take current… Continue Reading