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Category: Foreign Assets

Criminal Investigations and Penalties for IRS Offshore Disclosure

IRS criminal investigations

According to the IRS, the US loses several billions of dollars every year as a consequence of individuals who either hide or fail to report their offshore revenue or foreign earnings. Offshore tax fraud or tax evasion is a crime if it is determined to have been committed willfully and one can face certain penalties… Read more »

Foreign Asset Reporting Requirements

FARB reporting

Understanding Foreign Asset Reporting US tax code can be very confusing. This is especially true when it comes to reporting foreign assets. The IRS has a number of complex regulations regarding foreign assets and how they are reported, any of which can cause headaches for those filing. To give you some insight into the FBAR… Read more »

Do I Need To Report Bitcoin On My FBAR?

After a long period of relatively low scrutiny, probably because Bitcoin values were relatively stagnant, the cryptocurrency is now on the Service’s (IRS) radar. Under current “law,” and that is using the term loosely, Bitcoin is probably not reportable on FBAR forms. However, since this declaration comes not from Moses as he descended the mountain,… Read more »

Bye, Bye, Baby Elle: Is FATCA Inflexible?

FATCA Letters Don’t Discriminate At only 8 months old, Canadian-American Baby Elle has had to learn the hard way just how unforgiving the American global tax code system can be to those living/working outside the U.S.  Less than a year old, and Baby Elle has already received a Foreign Account Tax Compliance ACT (FATCA) letter regarding… Read more »

What US Expats Should Do with an Australian Superannuation

As a general rule, non-US retirement plans are tricky for US citizens. And you won’t find a trickier example than an Australian superannuation. If you participate in one already, in this article I’ll give you a few friendly suggestions regarding this unfriendly subject. But first, the two big reasons that superannuations are so tricky in… Read more »

Do You Qualify for the Streamlined Filing Compliance Procedures?

If you are a US  citizen or resident alien with undeclared or misreported non-US financial assets, the Streamlined Filing Compliance Procedures (SFCP) are your best way to come forward and get compliant – if you qualify. This article explains how to know if you’re eligible. The underlying cause of your problem is that you have… Read more »

Don’t Ignore Your Bank’s “Know Your Customer” FATCA Letter

Do you have US citizenship and a non-US bank account? By now you might have received a FATCA letter from your foreign bank asking about your US tax filing status. Why does your British (or German, or Australian, or wherever) bank care about whether or not you are following US tax rules? The short answer… Read more »

US Citizen with Foreign Life Insurance? Better Call Tax Ghostbusters

As a US tax lawyer, I see ghosts. Poltergeists, actually – the ghosts who cause real damage. The poltergeists are certain types of foreign financial assets which are perfectly normal outside the US. But they wander the separate dimension of US tax regulations and haunt the US citizens who brought them to life. Some of… Read more »