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

Tag Archives: FBAR

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 Issues New FBAR Guidance – Updated FAQs and New Streamlined Procedures for Low-Risk Cases

Posted in Compliance, General, International

The IRS published the anticipated update to the Frequently Asked Questions relating to the Offshore Voluntary Compliance Initiative (OVDI) relating to reporting of foreign financial accounts (commonly referred to as the “FBAR” reporting).  The guidance also includes favorable rules for (1) U.S. citizens living abroad and dual citizens with low compliance risks (generally less than… 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

New Regulations On Foreign Financial Account Reporting

Posted in International, Procedure

The IRS issued temporary regulations under the recently enacted section 6038D, Reporting of Specified Foreign Financial Assets.  Previously the IRS issued interim guidance in Notice 2011-55 and has also published draft Form 8938 instructions.  The statute and regulations are effective for tax years beginning after March 18, 2010.  In general, section 6038D requires individual taxpayers… Continue Reading

FBAR Voluntary Disclosure – IRS Provides Short-term Extension to September 9

Posted in Compliance, General, International, Litigation/Controversy

NOTE (Aug. 29, 2011): The IRS clarified that the Sept. 9, 2011, extension also applies to taxpayers filing delinquent FBARs pursuant to IRS Q&A 17 and 18 for the simplified program applicable to taxpayers who did not owe tax but failed to file the appropriate tax forms. _________________________________________________________ Due to Hurricane Irene, the IRS extended… Continue Reading

IRS Reminds Taxpayers of Aug. 31 Deadline for FBAR Voluntary Disclosure

Posted in Compliance, General, International, Litigation/Controversy

The IRS issued a press release reminding taxpayers that they have until August 31 to join the 2011 Offshore Voluntary Disclosure Initiative.  According to the press release, the 2011 initiative offers benefits to encourage taxpayers to come forward rather than risk detection by the IRS, observing that taxpayers hiding assets offshore who do not come… 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

June 30 FBAR Deadline Extended for Certain Persons

Posted in International

June 30th is the annual deadline for FBAR filing for certain persons with financial interest in, or signatory authority over, foreign accounts with balances over $10,000. Yesterday the government announced a one-year extension for a small subset of FBAR filers, namely certain employees of covered entities who have signature or other authority over accounts that… Continue Reading