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Bitcoin Accounts Not Required to be Reported on FBAR for 2013

Taxpayers with bitcoin accounts can breathe a small sigh of relief. According to the IRS, Bitcoin, also known as virtual currency, isn’t subject to FBAR reporting … at least for now. During a recent IRS webinar titled, “Reporting of Foreign Financial Accounts on the Electronic FBAR,” Rod Lundquist, Senior Program Analyst in IRS’s Small Business/Self Employed (SB/SE) division, stated […]

Getting to Know the Streamlined Domestic Offshore Procedures

U.S. taxpayers (or estates of individual U.S. taxpayers) seeking to use the Streamlined Domestic Offshore Procedures must satisfy the following requirements: (1) Fail to meet the non-residency requirement (for joint return filers, one or both spouses must fail to meet the non-residency requirement); (2) Have previously filed a U.S. tax return (if required) for each […]

The Good, the Bad, and the Ugly of the FATCA

If “FATCA” were a person and decided to enter a beauty pageant, it would be booed off the stage for being unsightly. If “FATCA” were a writer and decided to write a nonfiction book, it sure as heck wouldn’t be, “How to Win Friends and Influence People.” What is it about this petulant law that […]

OVDP or Streamlined: What Is My Best (Or Only) Option?

Recently, the IRS announced Streamlined Filing Compliance Procedures in order to encourage U.S. taxpayers to come into compliance with reporting their offshore financial accounts and assets. For eligible U.S. taxpayers residing outside the United States, all penalties are waived under the streamlined procedures. For eligible U.S. taxpayers residing within the United States, the only penalty […]

Do You Need To Report On An FBAR & Form 8938 Your Offshore Gold, Cash & Notes?

As has become obvious, the IRS has stepped up its efforts to curb non-disclosure of offshore assets and underreported income by U.S. taxpayers.  Tax compliance has risen to the top of the IRS agenda, and with widely publicized alerts from the IRS, claims of ignorance of the law aren’t likely to go very far. Contrary […]

Getting to Know the Streamlined Foreign Offshore Procedures

U.S. taxpayers seeking to use the streamlined foreign offshore procedures must satisfy the following requirements: The applicable non-residency requirement (for joint return filers, both spouses must satisfy the non-residency requirement); and Have failed to file an FBAR with respect to a foreign financial account; and The failure to file an FBAR must have resulted from […]

New Streamlined Filing Procedures: A Trap For the Unwary?

I recently attended the NYU’s Tax Controversy Forum.  Two of the panelists were officials from the IRS: Jennifer Best, Senior Advisor, IRS Large Business and International Division, and John McDougal, special trial attorney and division counsel, IRS Small Business and Self-Employed Division. Both offered insight into the newly expanded streamlined filing procedures.  One of the […]

Understanding the Streamlined Filing Compliance Procedures

On Wednesday, June 18, 2014, the IRS overhauled the Offshore Voluntary Disclosure Program while expanding and modifying the streamlined filing procedures in order to accommodate a broader group of U.S. taxpayers.  Major changes to the streamlined procedures include the following: (1) extension of eligibility to U.S. taxpayers residing in the U.S., (2) elimination of the […]

Transitioning From 2012 OVDP to Streamlined Compliance Procedures: Q & A

(1) What is the purpose of transitional treatment under OVDP? Transitional treatment under OVDP allows taxpayers currently participating in OVDP who meet the eligibility requirements for the expanded Streamlined Filing Compliance Procedures announced on June 18, 2014, an opportunity to remain in the OVDP while taking advantage of the favorable penalty structure of the expanded […]