Foreign Bank Account Reporting (FBAR) - FinCEN Form 114 FinCEN Financial Crimes Enforcement Network (FinCEN) is a bureau of the Treasury Department. Authorized under the Bank Secrecy Act, foreign bank account reporting commonly referred to as “FBAR†is electronically reported to the IRS via FinCen Form 114 separate and...
Foreign Financial Asset Reporting (FATCA) - Form 8938 was enacted March 18, 2010 and requires filing of Form 8938. The FATCA requirement does not replace or otherwise affect a taxpayer’s obligation to file an FinCEN Form 114. Basically if you are a US taxpayer holding foreign financial assets you...
Living and working outside of the USA - anyone can do it - everyone should....
In 1996, the U.S. Treasury Department issued T.D. 8671, 1996-1 C.B.314 introducing the ITIN - Individual Taxpayer Identification Number - requiring people foreign to the USA to use a unique identification number on their United States federal income tax returns. These regulations were intended to address concerns...
Call me naive but the immigration "problem" in the USA is rooted in the fact that the country offers the absolute best Social Security and Medicare systems on the planet. It is remarkable that millions of people, mostly good people in all other regards, are...
I was brought in on another interesting file this week involving a US Citizen seeking expatriation that I was strongly advised to run away from by my mentors and friends simply because it is easy to paint a picture of these types of folks as having...
As we increasingly become more connected on this planet US Taxpayers are compelled more than ever before to hold investments in multiple countries. As a direct result timely filing IRS Form 5471 is becoming profoundly significant. I've been involved with enough international tax matters to appreciate this...
In 2010, the Hiring Incentives to Restore Employment (HIRE) Act added Code Sec. 6038D requiring individual taxpayers with an interest in a specified foreign financial asset during the tax year to attach a disclosure statement to their income tax return for any year in which the aggregate...
Notice 2011-53, issued by Treasury and the IRS, provides a workable timeline for foreign financial institutions (FFI) and U.S. withholding agents to implement the various requirements of the Foreign Account Tax Compliant Act (FATCA). Â The notice phases in the implementation of FATCA in the following...
ACK: Alison Muecke To gather information for law enforcement, particularly drugs and organized crime, Congress has long required U.S. persons owning or having signatory authority over foreign financial accounts to file a report with the Department of the Treasury disclosing information about the accounts. The Report of...