Archive | FATCA/FBAR

Panama Papers Update – October 2016

October 11, 2016  |   Posted by :   |   FATCA/FBAR,Panama Papers   |   0 Comments

The Panama Papers were released in April 2016, outing the world’s wealthiest people, including celebrities, politicians and business leaders for hiding their wealth through Panama Law Firm, Mossack Fonseca, setups in world tax havens (currently 90 known world tax havens). The explosive revelations subsequently have included: 1) Up to $34 Trillion in Wealth, owned by […]

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The IRS & Offshore Trusts: FATCA

March 03, 2016  |   Posted by :   |   FATCA/FBAR   |   1 Comment

On March 18, 2010, President Obama signed the Hiring Incentives to Restore Employment Act (“HIRE”) Act (P.L. 111-147, the “Act”) which included the Foreign Account Tax Compliance Act (“FATCA”) which contained new foreign account tax compliance rules. Under the Act, new reporting and disclosure requirements for foreign assets were phased in between 2010-2014. Under FATCA: […]

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October 21, 2015  |   Posted by :   |   FATCA/FBAR   |   0 Comments

On 10/2/09, the IRS confirmed it has begun exchanging tax information from certain foreign governments under the Foreign Account Tax Compliance Act (“FATCA”), to meet a September 30, 2015 deadline ( over 5 years after FATCA was passed as law in March 2010). To date Australia has given the US tax information on 30,000 US […]

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IRS Offshore Account Penalties Go Up, More Banks Listed

August 06, 2015  |   Posted by :   |   FATCA/FBAR,Tax Evasion   |   0 Comments

IRS Offshore Account Penalties Go Up, More Banks Listed by Robert W. Wood, Since July 1, eleven more Swiss banks have entered deferred prosecution agreements with the U.S. government. The subject is tax evasion involving American account holders. Today, banks everywhere want to know if you are compliant with the IRS. Under FATCA, the […]

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IRS Issues New Examiner FBAR Penalty Guidance

July 30, 2015  |   Posted by :   |   FATCA/FBAR   |   0 Comments

The IRS issued new examiner FBAR penalty guidance (SBSE-04-0515-0025) effective 5/13/15 for all FBAR cases (Fincen Form 114) open as of that date. Most importantly, the examiner is allowed to increase the maximum penalty from 50% to 100% of the offshore account balance (plus interest). Effectively, with the penalty (and interest) on the unreported account […]

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The Foreign Account Tax Compliance Act (“FATCA”)

July 09, 2015  |   Posted by :   |   FATCA/FBAR   |   0 Comments

The Foreign Account Tax Compliance Act (“FATCA”) became law in March 2010 but implementation did not begin until February 2015 when foreign financial institutions began reporting US tax payer foreign accounts. FATCA targets tax non-compliance by the US Taxpayer with foreign accounts. If the US taxpayer does not report the account, and file Form 8938 […]

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FBAR Penalties (2015): Taxpayer Willfulness & Required Records Exception

April 28, 2015  |   Posted by :   |   FATCA/FBAR,Tax Evasion   |   1 Comment

For US taxpayers with Foreign Bank Accounts valued over $10k, a Fincen Form 114 must be electronically filed by June 30 each year. The penalties for failure to file are both civil and criminal and may include: 1) Failure to Report Foreign Bank and Financial Accounts (Form 1040/Schedule B, Part III, 7 (a)) which may […]

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10 Facts About FATCA, America’s Manifest Destiny Law Changing Banking Worldwide

September 05, 2014  |   Posted by :   |   FATCA/FBAR   |   0 Comments

by Robert W. Wood, Never heard of FATCA? You will. FATCA-the Foreign Account Tax Compliance Act-is America’s global tax law. It was quietly enacted in 2010, and after a four-year ramp up, it’s finally in effect. What is most amazing is not its impact on Americans-although that is considerable-but its impact on the world. […]

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FATCA – Intergovernmental Agreements

August 01, 2014  |   Posted by :   |   FATCA/FBAR   |   0 Comments

As of today’s date the U.S. government has signed 80 intergovernmental agreements (IGA). See link for complete list from Dept. of Treasury. The 80 IGAs will implement the Foreign Account Tax Compliance Act (FATCA) effective date 7/1/14. Under the IGA foreign governments will disclose their U.S. account holders whose accounts are in their country (and […]

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Court Upholds Record FBAR Penalties, Exceeding Offshore Account Balance

June 20, 2014  |   Posted by :   |   FATCA/FBAR,Tax Evasion,Unreported Income   |   0 Comments

In the case of Carl Zwerner a $1.69 million undisclosed offshore Swiss Bank account (ABN/AMRO) cost the Florida taxpayer $3.48 million for FBAR (and other) violations (i.e. two times the account value). The jury found Zwerner willful and imposed the FBAR 50% penalty. The Zwerner case confirms: 1. The IRS/OVDP risks (the taxpayer applied, was […]

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