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Category: International Tax Blog

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 »

Six Guidelines to Writing an SDOP / SFOP Statement of Facts that Will Be Accepted by the IRS

Don’t Be Turned Down for Streamlined Procedures When Trying to Resolve FBAR Reporting Problems If you are thinking about enrolling in the Streamlined Domestic Offshore Procedures (SDOP) or Streamlined Foreign Offshore Procedures (SFOP) in order to resolve delinquent or unresolved FBAR reporting, you will need to be ready to write your “complete story.” That’s because… Read more »

Disclosure Under International Tax Agreements and Tax Treaties

What Does an International Tax Agreement Actually Mean? If you are a US citizen living or doing business in a foreign country, that country probably has at least one international tax agreement with the US. The US has already concluded tax agreements with practically all of the so-called developed countries and the list continues to… Read more »

How the OVDP Works With Passive Foreign Investment Companies (PFIC)

PFIC Tax Rules – Disclosure Options when you Have Foreign Mutual Funds If you’re a U.S. citizen who has lived or done business outside the U.S. it may have seemed like a good idea to invest in a mutual fund over there, but you need to know the tax rules about passive foreign investment companies… Read more »

Foreign Real Estate and Offshore Disclosure Landmines

Most law-related information on the web comes with a disclaimer towards the end.  When discussing foreign real estate and offshore disclosure, though, I would put the disclaimer at the very beginning: It is strongly suggested that you talk to an attorney with experience in this area. Why at the beginning? Because I want to emphasize… Read more »

Willful on Non-Willful? What Happens Next in the 2015 SFCP or OVDP

The Difference Between Streamlined and full OVDP Think for a second about the Dakar Rally, the world famous off-road endurance race. Challenging terrain, customized vehicles, and long distances are all part of the show. It is obvious to any spectator that it is not an easy race. Drivers need years of experience to compete and… Read more »

Do I Need OVDP?

US Citizen Abroad: Which IRS Forms Should I Have Been Filing? Do I Need to Get Compliant? If you have ever lived outside of the United States you may have noticed that some American calendar dates like Martin Luther King’s Birthday, Columbus Day, or maybe even July 4th start becoming easier to forget. If you are… Read more »