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Tag: OVDP

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 »

Panama Papers: A Foreign Asset Disclosure Wakeup Call

The Panama Papers are a collection of documents that were leaked (which essentially means stolen) from Mossack Fonseca, a Panamanian law firm, in 2015 and hit the mainstream media in early 2016. The documents contained information about the offshore assets of a number of wealthy (and sometimes famous) account holders, and the press has mostly… Read more »

New IRS FAQs for OVDP, SFOP and SDOP

New Rules for How to Establish Non-Willfulness for Streamline Program and Other FAQ Updates The most recent updates to the FAQs for the Streamlined Foreign Offshore Procedures (SFOP) and Streamlined Domestic Offshore Procedures (SDOP) have all the trappings of a celebrity scandal, but in fact they serve a far more practical purpose. We’ll get there in… 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 »