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On September 8, 2023, the IRS announced a multitude of compliance initiatives aimed at high-income taxpayers, partnerships, digital assets, FBARs and labor brokers.  According to the announcement, the IRS has finalized its “top-to-bottom review” of current enforcement efforts and intends to zero in on these matters in the near future.  As expected, the impetus for change—according to the announcement—was Congress’s decision to provide the IRS with additional funding through its passage of the Inflation Reduction Act (IRA). …

On June 21, 2022, the United States Supreme Court agreed to hear a dispute involving split decisions among the circuit courts on non-willful penalties. The Fifth Circuit parted ways with the taxpayer friendly decision of the Ninth Circuit that non-willful penalties are capped at $10,000 per FBAR filing instead of the $10,000 per unreported bank account argued by the government. District courts in New Jersey, Connecticut, California, and Texas had all ruled in the taxpayer’s favor that non-willful penalties were capped at $10,000 per form as well.  The case headed to the Supreme Court is United States v. Bittner, where a taxpayer friendly decision from the District Court reduced the $2.7 million penalty to $50,000 based on a $10,000 per form cap on non-willful FBAR penalties.  The Fifth Circuit reversed the favorable district court decision and held that the “$10,000 penalty cap therefore applies on a per-account, not a per-form basis.”…

There is absolutely nothing wrong with having a foreign bank account.  The problem comes along when the existence of the account is not disclosed and income associated with the account is not reported.

You have probably heard about people “stashing” money in overseas or offshore bank accounts.  The United States is actively working to uncover…

The IRS continues to aggressively pursue offshore tax evasion.  Another example of which is plan to share tax information with Australia and the United Kingdom.  The announcement says that the target is trusts and companies holding assets on behalf of residents throughout the world.

Popular countries used to create of trusts and other entities according…

GorillaThere is a plethora of forms and reports that need to be filed with the IRS if you do business or have personal assets abroad.  Examples of situations include when:

  1. You have an interest in or signatory authority in financial accounts
  2. You have specified foreign assets
  3. You own all or part of a foreign corproation

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