IRS delinquent FBAR submission procedure

- By : P. Patel

Last spring, the IRS revised its program for delinquent FBAR returns. The IRS offers a new “delinquent FBAR submission procedure”.  See below excerpt from the IRS website.The program is available if you properly reported on your U.S. tax returns, and paid all tax on, the income from the foreign financial accounts reported on the delinquent

Top FBAR Reporting Error

- By : P. Patel

The most common FBAR reporting mistake is simply failing to file. Some U.S. persons continue to deliberately conceal assets in secret offshore bank accounts in the hope of evading U.S. tax authorities. In many other cases, however, Americans living and working outside the U.S., recent immigrants, foreign citizens who are resident in the U.S., and

Correcting Common FBAR Errors

- By : P. Patel

The IRS offers four options to fix FBAR mistakes. Participation in the two formal disclosure programs is permitted only if the funds held in the foreign financial account(s) are from a legal source (and not the proceeds of an illegal activity) and if the IRS is not already in a position to know of the

New FBAR FIling Deadline Law Signed

- By : P. Patel

The president signed into law today legislation that modifies the due dates for several common tax returns.  These new due dates are generally ones that tax professionals have been advocating for several years to create a more logical flow of information and help taxpayers and tax professionals in filing timely and accurate tax returns. The

Top 4 Exceptions to FBAR Filing Requirement

- By : P. Patel

FBARs are due this week (again).  Below are the top 4 exceptions we often see for the FBAR filing requirement.  Certain Accounts Jointly Owned by Spouses – the spouse of an individual who files an FBAR is not required to file a separate FBAR if (1) all the financial accounts that the non-filing spouse is

Beware: IRS Reminds Taxpayers of FBAR Deadline

- By : P. Patel

Last week, the Internal Revenue Service reminded all taxpayers with a filing requirement for a foreign bank account report to report their foreign assets by the June 30 deadline.  The IRS has been targeting FBAR compliance over the last several years and has prosecuted numerous non-compliant taxpayers. FBAR filings have risen dramatically in recent years

New IRS Guidelines for Willful FBAR violations

- By : P. Patel

Last week, the Internal Revenue Service released interim guidance (SBSE-04-0515-0025) on foreign bank account report (FBAR) penalties to improve the administration of the FBAR compliance program. The guidance contains amendments to the Internal Revenue Manual (IRM), effective immediately, and applies to all open cases in which the FBAR penalties are at issue. Examiners are required to

New Much-Needed Guidance for Non-Willful FBAR violations

- By : P. Patel

Last week, the Internal Revenue Service released interim guidance (SBSE-04-0515-0025) on foreign bank account report (FBAR) (also known as FinCen 114) penalties to improve the administration of the FBAR compliance program. The guidance contains amendments to the Internal Revenue Manual (IRM), effective immediately, and applies to all open cases in which the FBAR penalties are at

Another Taxpayer Found Guilty of Failure to File FBARs and Report Foreign Income

- By : P. Patel

Raju Mukhi of St. Louis MO was indicted last year for his alleged failure to file a report to the IRS on his foreign financial accounts and for filing false tax returns. United States citizens are required to report income from foreign countries, such as bank account, securities and any other financial accounts on their

Helpful Non-willful FBAR penalty case decided by court

- By : P. Patel

For the first time, in the case of James Moore, Plaintiff v. United States of America, Defendant (James Moore v. U.S. Case 2:13-cv-02063-RAJ filed 4/1/15), we finally get a look at some non-willful FBAR penalty litigation. The US district court has essentially dismissed a taxpayer’s challenges to his penalty for failing to file FBARs (Report