Contents1 FBAR Penalty Calculations2 Understanding How FBAR Penalties Work3 What does that all Mean?4 FBAR Penalty Mitigation5 FBAR – A Brief History6 Filing an FBAR7 What Are FBAR Penalties?7.1 Non-Willful7.2 Willful8 What is the Legal Standard for Willful and Non-Willful?8.1 Willful does NOT mean Intent or Knowledge8.2 Willfulness Can Mean Willful Blindness:8.3 Reckless Disregard9 Why Are…
Contents1 What Does an FBAR Attorney do?2 FBAR Attorney3 FBAR – More than Reporting Foreign Accounts4 FBAR – Foreign Account Reporting5 FBAR – Three (3) Main Issues we come across5.1 Previously Opened Account5.2 Accounts in a “Home Country” or “Country of Citizenship5.3 $10,000 Aggregate Total of All Accounts6 Penalties6.1 Non-Willful6.2 Willful7 What is the Legal…
Contents1 Offshore Tax Compliance2 What is Offshore Tax Compliance?3 My Accounts & Assets Pre-Date Citizenship/U.S. Residency4 Examples Reporting vs. Tax4.1 Bank Account Reporting4.2 U.S. Tax on Foreign Income5 Foreign Interest Income6 What Happens if I do not Report?7 IRS Offshore Voluntary Disclosure Offshore Tax Compliance The Internal Revenue Service has made the enforcement of offshore…
Contents1 OVDP Program2 OVDP – Not Just Foreign Accounts3 What Must be Reported?4 What if I do not get into IRS Offshore Compliance?5 10 Key Reporting Requirements6 Reporting Foreign Accounts (FBAR)7 FATCA Form (8938)8 Foreign Gift Form (3520)9 Foreign Corporation or Foreign Partnership (5471 or 8865)10 Passive Foreign Investment Company (PFIC) or Form 8621 11 Foreign…
Contents1 IRS Passport Revocation or Denial2 FEIE and FTC3 Will You Get “Caught”4 Steven – U.S. Person Abroad (Accidental Americans)5 Michelle – Legal Permanent Resident (Small Business Owner)6 IRS Offshore Voluntary Disclosure IRS Passport Revocation or Denial IRS Passport Revocation and IRS Passport Denial is a sad, but true reality. As you may or may not…
Contents1 FBAR Bitcoin 2 Prior guidance was for Prior years 3 A Bitcoin Wallet is an Account4 The IRS is Actively Seeking out Bitcoin Wallet owners5 People Suck…Meet the Whistleblowers6 Closing The Account is Not Your Best Strategy7 Be Careful. FBAR Bitcoin While the law is not concrete on the issue of filing FBARs for Bitcoin Accounts/Wallets,…
Contents1 FBAR Amendments2 I Forgot a Few Small Accounts3 I Forgot a Small Accounts and Interest/Dividends4 Investment Accounts, Insurance, Pension5 I Knew (or Should Have Known) and Now I want to Report6 FBAR Audit Trigger7 FBAR Penalties Can Be Serious8 Be Careful What You Read!9 FBAR Audit Trigger Example – Michael From India9.1 Myth 1:…
Contents1 Offshore Voluntary Disclosure Program2 Offshore Disclosure Assets and Investments3 What Must be Reported to the IRS3.1 Some examples of assets that must be reported include:4 Exceptions & Exclusions Often Do Apply4.1 PFIC4.2 Foreign Real Estate4.3 Foreign Retirement5 What if the Money is Exempt overseas?6 Penalties6.1 The following is a summary of penalties as published by…
Contents1 Offshore Voluntary Compliance2 Offshore Voluntary Disclosure Program (OVDP)2.1 Reduced Chance of IRS Audit or Examination2.2 Reduced Chance of Criminal Investigation or Prosecution3 OVDP Penalty Amount3.1 Three (3) Common Questions Regarding the OVDP Penalty4 Penalty Opt-Out5 Streamlined Filing Compliance Procedures6 Streamlined Domestic Offshore Procedures (SDOP)7 Streamlined Foreign Offshore Procedures (SDOP)8 Conclusion8.1 FBAR 8.2 Form 89388.3 Form…
Contents1 Foreign Earned Income Exclusion Background2 Time Expires for Claiming the Exclusion3 How to Qualify4 Must be Earned Income4.1 Physical Presence Test (330 Days)4.2 Bona-Fide Resident5 How the Exclusion Works6 Foreign Housing7 Tax8 Foreign Tax Credit9 Passive Income Foreign Tax Credit10 Unreported Foreign Assets, Accounts and/or Income In general, the Foreign Earned Income Exclusion is the preferred…
Contents1 IRS Tax Amnesty2 IRS Rules for Offshore or Foreign Income3 Offshore Voluntary Disclosure Program4 OVDP Streamlined (aka“ IRS Streamlined Program”)5 OVDP Forms vs. Streamlined Forms6 Streamlined 14453 vs. 144547 OVDP Penalty Calculation8 Streamlined Penalty Calculation9 Offshore Voluntary Disclosure – The Basics IRS Tax Amnesty IRS Tax Amnesty is the process of getting to compliance with your…
Contents1 Foreign Bank Account Reporting2 Who Has to Report?3 Seriousness of Foreign Bank Account Reporting4 Foreign Account Reporting – The Basics5 A Snapshot of Your Account Value6 Other Common Types of Foreign Asset Reporting7 Reporting Foreign Accounts (FBAR)8 FATCA Form (8938)9 Foreign Gift Form (3520)10 Foreign Corporation or Foreign Partnership (5471 or 8865)11 Passive Foreign…
