FATCA Deadlines Extended

- By : Parag Patel

Many of our tax-noncompliant clients are fearful of being involuntary discovered through the impending FATCA disclosures of their foreign accounts by their foreign banks. The Internal Revenue Service has issued…

Top myths of US tax compliance for Foreign Accountholders

- By : Parag Patel

FATCA is not a tax. FATCA does not focus on income, tax rates, or tax liability. FATCA seeks to identify U.S. investors with foreign financial interests, making it easier for…

Republican Party Rallies Against FATCA: Success Unlikely

- By : Parag Patel

…Republican Senator Rand Paul last year introduced legislation to repeal parts of FATCA, citing privacy concerns. Defending the law, US Treasury Department spokeswoman Erin Donar said in a statement: “FATCA

Beware IRS Letter 6291

- By : Parag Patel

…the foreign financial accounts on form 8938 statement of specified foreign financial assets you held with [Bank Name].” This letter is an IRS “soft letter” (i.e., a warning letter) to…

The Dreaded IRS Letter 6185: “We received information that you have a foreign account”

- By : Parag Patel

…foreign financial accounts, foreign entities, or foreign financial assets.” This letter is an IRS “soft letter” (i.e., a warning letter) to U.S. taxpayers owning foreign accounts. These soft letters indicate…

IRS Announces Key Milestone in FATCA Implementation; U.S. Begins Reciprocal Automatic Exchange of Tax Information under Intergovernmental Agreements

- By : Parag Patel

…is a major milestone in IRS efforts to combat offshore tax evasion through FATCA and the intergovernmental agreements,” said IRS Commissioner John Koskinen. “FATCA is an important tool against offshore…

No More Delays for FATCA: Get Ready for Disclosure

- By : Parag Patel

The US Foreign Account Tax Compliance Act (FATCA) will definitely come into effect on 1 July this year with no possibility of further delay, according to officials of the US…

Argue for No Penalty and a Warning Letter for FBAR Violations

- By : Parag Patel

letter, Letter 3800, or determine a penalty. Penalties should be asserted only to promote compliance with the FBAR reporting and recordkeeping requirements. In exercising their discretion, examiners should consider whether…

India issues FATCA Self-certifications and KYC Warnings

- By : Parag Patel

…Foreign Account Tax Compliance Act (FATCA). FATCA is part of the U.S.’s answer to tracking money hidden in offshore accounts so it can be brought into the US tax net….

US FATCA Enforcement Softens due to Coronavirus

- By : Parag Patel

…the Foreign Account Tax Compliance Act, or FATCA, because of the coronavirus pandemic. The Internal Revenue Service on Wednesday extended from March 31, 2020 to July 15, 2020 the deadline…

Are You Ready For New FATCA Enforcement in 2020?

- By : Parag Patel

…may now see those accounts closed or frozen. FATCA FATCA is a U.S. federal law that aims to prevent U.S. corporations and individuals from hiding assets in foreign U.S. accounts…

Vatican Signs FATCA Agreement

- By : Parag Patel

Praying may not be enough for non-compliant taxpayers (or evaders) under the Foreign Account Tax Compliance Act (FATCA). The Vatican has become the latest FATCA signatory to share bank information…

Letter to Your Spouse

- By : Parag Patel

…knows where to find the letter. Letter to My Spouse Dear Spouse, As we have discussed, you should use this letter (which is not to be misconstrued as my will)…

Opting Out of the OVDI Program: Argue for No Penalty and a Warning Letter

- By : Parag Patel

…results for some of our clients. Under IRM 4.26.16.4 (FBAR Penalties) (07-01-2008) whenever there is an FBAR violation, the examiner will either issue the FBAR warning letter, Letter 3800, or…

New FATCA / CRS reporting penalties in India

- By : Parag Patel

…KYC (Know Your Customer) including information provided in FATCA and CRS questionnaire. The new budget proposes a penalty of Rs.5,000 if there is any inaccuracy in the statement of financial…

FATCAts

- By : Parag Patel

…first phases of FATCA implementation beginning in January 2013, FATCA will require all non-US ‘foreign financial institutions’, including banks, brokerage houses, hedge and private equity funds, trust companies and perhaps…

Canada and US sign FATCA tax deal where banks to share information with IRS

- By : Parag Patel

…signed an intergovernmental agreement (“IGA”) with the US regarding the US Foreign Account Tax Compliance Act (“FATCA”). FATCA requires U.S. financial institutions to impose a 30 percent withholding tax on…

ABA COMMENTS ON THE 2014 OFFSHORE VOLUNTARY DISCLOSURE PROGRAM AND THE STREAMLINED PROGRAMS

- By : Parag Patel

…(“FATCA”). Indeed, one of the criteria for identifying potential U.S. persons under the FATCA regulations and the Intergovernmental Agreements is whether the person was born in the United States.  …

Internal Revenue Service announces new International Data Exchange Service: The Beginning of Information Sharing

- By : Parag Patel

…complying with FATCA can be found at FATCA – Archive. The fact that 145,000 banks have registered and are providing government help to the IRS means that no foreign account…

India and the US have agreed to collaborate on offshore tax evasion

- By : Parag Patel

…believed to have foreign contacts for a FATCA Compliance Certificate. Technically, there is no FATCA Compliance Certificate, per se. Practically speaking, a FATCA Compliance Certificate simply refers to that indicates…

Bank Leumi: Another Foreign Bank Recommends the IRS Voluntary Disclosure Program

- By : Parag Patel

…media, U.S. authorities are conducting investigations of foreign banks in connection with compliance with U.S. tax laws,” the bank said in the letter. The Leumi letter to clients said: “The…

Trinidad and Tobago and the United States sign new agreement to exchange of information under FATCA

- By : Parag Patel

Last week Trinidad and Tobago and the United States signed an agreement to facilitate automatic exchange of information under the US Foreign Account Tax Compliance Act (FATCA). FATCA, enacted by…

New Report: Delinquent Taxpayers Could be Identified at US Border Crossings

- By : Parag Patel

…assets. In addition, there are over 78,000 global financial institutions that have entered into direct information exchange agreements with the IRS. These institutions will be issuing FATCA letters to U.S….

HSBC Payment of Largest Penalty and FATCA Encourages Taxpayers to Disclose

- By : Parag Patel

…be seen through bilateral agreements such as the adoption of the Foreign Account Tax Compliance Act (FATCA) between the United States and the UK, Denmark, Mexico, and many other nations….

Denied access to or withdrew from the IRS Offshore Voluntary Disclosure Program (OVDP)?

- By : Parag Patel

…including examination and letters. Taxpayers who receive the letter have three options for complying. Option #1 is to make a submission under the Streamlined Filing Compliance Procedures (HERE) if they…

Watch Out for Letters From Your Foreign Bank Requesting Information On Your U.S. Residency

- By : Parag Patel

…they are required to obtain such personal information pursuant to the U.S. Foreign Account Tax Compliance Act (“FATCA”) FATCA requires that foreign banks submit information to the United States government…

New IRS Enforcement Letters Warn of Cryptocurrency Non-Compliance

- By : Parag Patel

…these letters. The names of these taxpayers were obtained through various ongoing IRS compliance efforts. For taxpayers receiving an educational letter, there are three variations: Letter 6173, Letter 6174 or…

Citizenship renunciation fee increases as American expatriates flee FATCA

- By : Parag Patel

…rise in renunciations triggered by the US Foreign Account Tax Compliance Act. FATCA forces foreign banks and other institutions to report their US clients’ financial doings to the Internal Revenue…

Helpful Non-willful FBAR penalty case decided by court

- By : Parag Patel

…his counsel provided detailed arguments in a letter as to why Mr. Moore acted with reasonable cause In December of 2012, IRS responded in a brief letter upholding the penalties…

IRS Announces New Rules for FBAR Penalties

- By : Parag Patel

…examination; FBAR issue workpapers; the FBAR 30-Day Letter (Letter 3709 for pre-assessment; Letter 3708 for post-assessment); the Taxpayer’s protest; the representatives FBAR/Title 31 Power of Attorney Form 2848, if applicable;…