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5 Feb 2015, 11:30 am
" What are the potential consequences of FBAR non-compliance or other tax problems? [read post]
30 Jan 2015, 11:30 am
This is chiefly because Streamlined OVDP requires a certification that that taxpayer's failures to report, pay taxes, and file FBAR were due to "non-willful" conduct. [read post]
15 Jan 2015, 4:36 pm by Charles (Chuck) Rubin
This report highlights areas of tax law and IRS administration that are not in compliance with law or that require improvement. [read post]
11 Jan 2015, 4:42 pm by Kelly Phillips Erb
For now, the IRS has taken the position that “The Financial Crimes Enforcement Network, which issues regulatory guidance pertaining to Reports of Foreign Bank and Financial Accounts (FBARs), is not requiring that digital (or virtual) currency accounts be reported on an FBAR at this time but may consider requiring such accounts to be reported in the future. [read post]
5 Jan 2015, 3:31 pm by nedaj
www.colefrieman.com December 29, 2014 Clients, Friends, Associates: December is the busiest month of the year for most private fund managers. [read post]
4 Jan 2015, 8:10 pm by Kelly Phillips Erb
Three months later, the IRS clarified that Bitcoin was not reportable for FBAR purposes – at least for now. (4) Those Not-So-Missing Emails. [read post]
21 Nov 2014, 3:16 pm by Gene Takagi
Finally, Ripperda identified the 5 key focus areas of the Exempt Organizations Unit regarding compliance: (1) exemption issues; (2) protection of assets (including diversions); (3). tax (UBIT and employment); (4) international activities (terrorist, FBAR filings); and (5) emerging issues. [read post]
18 Nov 2014, 6:00 am
The purpose of the OVDP program is for individuals who have failed to file an FBAR (Foreign Bank and Financial Accounts Report) form with the IRS, or didn't report income from offshore activities to disclose their errors and to avoid criminal tax prosecution. [read post]
16 Oct 2014, 10:00 am
These programs are first cousins of the IRS' Offshore Voluntary Disclosure Program (OVDP), but technically are not part of OVDP, and are options for individuals who have failed to report income from offshore bank accounts, and who may have failed to file a Foreign Bank Account Reports, FinCEN Form 114, formerly TDF 90-22.1 (FBAR) or other international information reporting returns. [read post]
15 Oct 2014, 6:02 pm by Charles (Chuck) Rubin
For any year in which a foreign financial account was FBAR compliant and (for the mos [read post]
16 Sep 2014, 10:00 am
They must also file a FBAR (Report of Foreign Bank and Financial Accounts) on FINCen Form 114 disclosing any financial account in a foreign country with assets in excess of $10,000. [read post]
3 Sep 2014, 10:00 am
Although not mentioned in the press release, one would assume that Sathre also failed to file Foreign Bank Account Reports (FBARs) on TD-F 90-22.1 (now known as FinCEN Form 114). [read post]
9 Aug 2014, 8:49 am by Charles (Chuck) Rubin
The IRS’ newly announced procedures fail to provide adequate guidance as the difference between “willful” and “non-willful” FBAR violations. [read post]
3 Aug 2014, 4:28 pm by Charles (Chuck) Rubin
For example, if the IRS determines that there was an existing IRS investigation, or omitted income, or, perhaps if the IRS disagrees with the reasonable cause statement and finds the FBAR was intentionally not filed, it might impose civil and criminal penalties. [read post]
24 Jul 2014, 1:04 pm by Charles (Chuck) Rubin
Further, submissions won’t qualify under the New Procedures, if the taxpayer is under an IRS examination, civil or criminal, or if the IRS finds that the entities were used for tax evasion. [read post]
18 Jul 2014, 10:40 am by nedaj
According to the IRS FBAR Reference Guide, foreign hedge funds and private equity funds are generally not reportable on the FBAR. [read post]
17 Jul 2014, 12:26 pm by Charles (Chuck) Rubin
Rather, the Delinquent FBAR procedures make it clear that if a delinquent FBAR submission is examined by the IRS, civil FBAR penalties and even criminal prosecution may result. [read post]