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19 Nov 2011, 1:51 pm
Form 8938 will most likely be an essential tool in auditing by the IRS. [read post]
11 Nov 2011, 6:00 am
If that is the case then it may be too late for these individuals to file a Foreign Bank Account Reports (FBAR) on TDF 90-22.1. [read post]
6 Nov 2011, 12:05 pm
In the two recent voluntary disclosure programs offered by the IRS, 2009 and 2011, the IRS created a “miscellaneous civil penalty”, in lieu of FBAR penalties, to allow it to administer the voluntary disclosures under the IRC. [read post]
30 Oct 2011, 2:05 pm
The cost of coming forward varies by program, but for the IRS programs, the 2009 FBAR settlement was 20% of the highest aggregate foreign account balance during years 2003-2008. [read post]
23 Oct 2011, 10:53 am
They would need to file a gift tax return (Form 709) and if the cumulative amount of the gifts exceeded $60,000 then they would have to write a check to the IRS. [read post]
23 Oct 2011, 8:37 am
Informal advice from various sources in the IRS and IRS Criminal Investigation are suggesting that taxpayers with unreported foreign bank accounts, and unfiled FBAR’s go through the IRS Criminal Investigation “preclearance” process and then file the voluntary disclosure letter without knowing what the rest process will be. [read post]
16 Oct 2011, 10:43 am
One of the key questions in the IRS Offshore Voluntary Disclosure letter is “source of funds”. [read post]
11 Oct 2011, 3:46 pm
According to a report in the Swiss newspaper Swiss Bank accounts over to the IRS, and/or the Department of Justice. [read post]
9 Oct 2011, 12:56 pm
The reasonable cause for not filing FBAR’s does not go to failure to include gambling winnings in income, however. [read post]
3 Oct 2011, 7:00 am
Jail time for criminal tax violations, or failure to file TDF 90-22.1 (FBARs), and ruinous [read post]
2 Oct 2011, 6:14 pm
The IRS in its FBAR Frequently Ask Questions (No.51 ) discusses the basis upon which a taxpyaer might “opt out of the offshore voluntary disclosure program. [read post]
22 Sep 2011, 1:28 pm
Unlike the voluntary disclosure process, the taxpayer does not alert the IRS that he will be filing the returns and FBARs. [read post]
18 Sep 2011, 7:31 pm
And the IRS prefers to go after jaywalkers with shotguns (with regards to FBAR violations). [read post]
18 Sep 2011, 3:04 pm
The IRS in its OVDI Frequently Asked Questions (51.1) suggests that some taxpayers, meeting the specific fact pattern should “opt out” as the total penalty calculation will be less under the FBAR civil penalty program. [read post]
10 Sep 2011, 2:07 pm
IRS and DOJ are more likely to take hardline positions on penalties for non-filers of FBAR’s and information returns, like the Report of Foreign Gifts/Inheritance and the returns for controlled foreign corporations. [read post]
6 Sep 2011, 12:56 pm
September 9, 2011 is the last date for taxpayers to submit requests to participate in the IRS Second Supplemental Offshore Voluntary Disclosure Initiative (OVDI). [read post]
31 Aug 2011, 7:30 pm
IRS Issues Draft Form 706 for 2010 Estates [By: Armstrong Teasdale |In: Tax Law] 5. [read post]
28 Aug 2011, 9:54 am
An FBAR is not an income tax form, it is a Bank Secrecy Act form and there is no direct mention on the USCIS/IRS link about FBAR filing obligations the failure to file an FBAR may be particularly troublesome to applicants under the EB-5 immigrant visa process. [read post]
27 Aug 2011, 3:44 am
You can also contact the IRS directly by calling 800-800-2877 and selecting option 2 or emailing FBARquestions@irs.gov (questions only to this email address, the system doesn’t accept actual FBARs). [read post]
24 Aug 2011, 7:27 am
One question that has interested individuals residing in Canada who are impacted by FBAR (Form TD F 90-22.1) is whether the Canadian tax authorities would collect penalties on behalf of the IRS. [read post]
