In a press release trumpeting the successful collection of more than $4.4 billion in its 2009 and 2011 voluntary disclosure programs, the IRS announced it is starting its third program designed to help people hiding offshore accounts get current with their taxes in the U.S. (IR-2012-5). The new program, unlike
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TOPICS / TAX
International tax
Foreign Financial Asset Reporting Form Finalized
The IRS on Saturday released the final version of Form 8938, Statement of Specified Foreign Financial Assets, and released its instructions on Monday. Affected taxpayers must use the form to report certain financial assets to the IRS. Last week, the IRS released temporary and proposed regulations on the new reporting
Regulations Issued for Specified Foreign Financial Assets Reporting
The IRS issued temporary and proposed regulations (T.D. 9567; REG-130302-10) on the requirement that certain foreign financial assets be reported to the IRS for tax years beginning after March 18, 2010. Sec. 6038D requires individuals to report interests in “specified foreign financial assets” (SFFAs) when filing their federal income tax
IRS Reminds Dual Citizens and Americans Living Abroad of FBAR, Other Filing Requirements
In a fact sheet (FS-2011-13) released Friday, the IRS reminded U.S. citizens and dual citizens of the United States and foreign countries who live abroad about U.S. filing requirements, including Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR). Some dual-citizen taxpayers may have only recently learned
Regs Shut Down Artificially Generated FTCs
The IRS issued final, temporary and proposed regulations providing guidance on determining the amount of taxes paid for purposes of determining the foreign tax credit. The regulations are designed to curb certain transactions that the IRS says “produce inappropriate foreign tax credit results.” The final regulations (TD 9535), issued July
FATCA Reporting Suspended for Some; Pre-2010 FBAR Filing Extended
The IRS suspended FATCA (Foreign Account Tax Compliance Act) information reporting requirements for certain individuals with foreign assets and shareholders of passive foreign investment companies (PFICs) under IRC §§ 6038D and 1298(f) (Notice 2011-55). The requirement will be suspended until the IRS releases Form 8938, Statement of Specified Foreign Financial
IRS Clarifies Sept. 9 Extension for Offshore Reporting
The IRS on Monday clarified its postponement of deadlines under the 2011 Offshore Voluntary Disclosure Initiative (OVDI). On Friday, in response to Hurricane Irene, the IRS moved the OVDI deadline to Sept. 9 (from Aug. 31), but did not address the Aug. 31 due date for information filings that are
Hurricane Postpones IRS’s Offshore Voluntary Disclosure Deadline
As Hurricane Irene was about to make landfall in North Carolina on Friday evening and head up the East Coast, the IRS announced it had postponed the deadline for its 2011 Offshore Voluntary Disclosure Initiative (OVDI). The new due date for requests is Sept. 9, 2011. Before the extension, taxpayers
“Killer B” Crackdown Finalized
The IRS issued new final regulations on cross-border reverse triangular reorganizations, popularly known as “Killer B” transactions (TD 9526). The regulations finalize with some modifications proposed regulations that were issued in 2008 (REG-136020-07). Previously, in Notices 2006-85 and 2007-48, the Service had said new rules were needed to thwart the
FinCEN Creates FBAR E-Filing System
The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) on Monday said it has developed an electronic filing system for Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR). The reports can now be filed via FinCEN’s BSA E-Filing System. A United States person who has a financial
Final Regulations Issued on Determining Amount of Tax Paid for Foreign Tax Credit Purposes
Final regulations issued on Wednesday provide guidance on determining the amount of taxes paid for purposes of determining the foreign tax credit (TD 9535). The regulations are designed to curb certain transactions that, the IRS says, “produce inappropriate foreign tax credit results.” The final regulations adopt proposed regulations issued in
IRS Suspends Foreign Asset, Passive Foreign Investment Company Information Reporting Rules
The IRS announced on Tuesday that it is suspending the information reporting requirements for certain individuals with foreign assets and shareholders of passive foreign investment companies (PFICs) under IRC §§ 6038D and 1298(f) (Notice 2011-55). The requirement will be suspended until the IRS releases Form 8938, Statement of Specified Foreign
FinCEN Grants Another FBAR Extension for Some Individuals
The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) on Friday released Notice 2011-2, which gives another small subset of individuals with only signature authority over certain foreign financial accounts who are required to file Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR), with respect to those
IRS Further Extends Deadline for Certain 2009 and Earlier FBARs
The IRS has further extended the deadline for certain persons to file Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR), for 2009 and earlier years (IRS Notice 2011-54). The new filing deadline is Nov. 1, 2011. The extension applies to persons with signature authority over a
IRS Eliminates Form 5472 Duplicate Filing Requirement
On Thursday, the IRS issued temporary and proposed regulations to remove the duplicate filing requirement for Form 5472, Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business (TD 9529 and REG-101352-11). Under the current final regulations, corporations that are required
FinCEN Clarifies Parties Entitled to FBAR Filing Extension
The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a revised notice Monday that clarified that a small subset of individuals are entitled to a one-year extension of the June 30, 2011, filing deadline to file Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR). The notice
Regulators Extend FBAR Filing Deadline for Certain Financial Professionals
The IRS and the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced Tuesday that a small group of individuals required to file the Report of Foreign Bank and Financial Accounts (FBARs) will receive a one-year extension beyond the upcoming filing date of June 30, 2011. FinCEN issued Notice 2011-1 that
IRS Announces “Good Faith” Extension of Voluntary Disclosure Deadline
The IRS said on Thursday that it is making available to taxpayers a 90-day deadline extension to participate in the 2011 offshore voluntary disclosure initiative (OVDI). The extension would be available to taxpayers who have made a good faith attempt to fully comply by Aug. 31, but are unable to
New “Killer B” Regulations Issued
The IRS has issued new final regulations on cross-border reverse triangular reorganizations, popularly known as “Killer B” transactions (TD 9526). The regulations finalize with some modifications proposed regulations that were issued in 2008 (REG-136020-07). Killer B transactions are designed to allow corporations to repatriate foreign subsidiary earnings tax-free, in violation
FinCEN Amends BSA Regs on FBAR Filings
The Financial Crimes Enforcement Network (FinCEN) issued a final rule (tinyurl.com/4tevafd) that amends the regulations under the Bank Secrecy Act (BSA) regarding Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR), to clarify when an account is foreign and therefore reportable as a foreign financial account and
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