What does it mean for the taxpayer to have “signature authority” over a foreign financial account?
A person has a “financial interest” in a foreign account not only if he is the owner of record or holder of legal title, but also if he has signatory authority of the account or maintains it jointly with another person. Signature authority is the authority of an individual to control the disposition of assets […]
What Does A Financial Account Include For FBAR-Reporting Purposes?
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What does it mean for the taxpayer to have a “financial interest” in a foreign account?
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The Rules Governing Taxation of Foreign Nationals
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Walking The Sawdust Trail
Those who responded to the altar call after one of Billy Sunday’s sermons were said to walk the sawdust trail, because the temporary venues he preached in back in the 1910s and 1920s often had sawdust on the floor as a deodorizer. Before he became a travelling evangelist, and possibly even before he became a […]
Is Making A “Quiet Disclosure” In Today’s Environment A Smart Choice For A Taxpayer with An Undisclosed Foreign Account?
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The Essence of The IRS’s Voluntary Disclosure Program
The objective of the Offshore Voluntary Disclosure Program (OVDP) is to bring taxpayers that have used undisclosed foreign accounts and undisclosed foreign entities to avoid or evade tax into compliance with United States tax laws. It enables noncompliant taxpayers to resolve their tax liabilities and minimize their risk of criminal prosecution. To do so, a taxpayer must walk […]
State Offshore Voluntary Disclosure – Because One Tax-osaurus Rex Wasn’t Enough
The Tax-osaurus Rex, or the fearsome offshore voluntary disclosure programs, has made thousands of taxpayers panic since it smashed through the scene a few years ago. While some chose to run and probably ended up torn to parts by vicious raptors (collectors), others are trying to survive by disclosing their foreign accounts and making up […]
Changes to FBAR Are Right Around The Corner
Back on March 10, 2016, the Financial Crimes Enforcement Network (FinCEN) proposed rules that would trigger changes to the current reporting requirements for Form 114. It is anticipated that these proposed rule changes will become final well before the new April 15, 2017 deadline for the FinCEN Form 114. The proposed regulations as published in the Federal […]
What Are My Options If I Am Fully Compliant With My FBAR Filing Requirements But Not Compliant With My Other International Information Returns?
Taxpayers who are fully compliant with their FBAR Filing Requirements but who are not compliant with their other international information returns, such as Form 3520, Form 3520-A, Form 5472, Form 926, Form 8865, are not suitable candidates for the streamlined procedures or for the Offshore Voluntary Disclosure Program. Instead, they should file the appropriate delinquent information returns […]