Foreign Accounts Compliance

U.S. Tax Compliance Concerning Foreign Income, Accounts, and Entities

United States citizens and residents (“U.S. persons”) need to comply with two U.S. statutory schemes concerning foreign income, accounts, and ...
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Taxpayer Wins FBAR Penalty Case

In 2012, Alexandru Bittner filed FinCEN Forms 114, Report of Foreign Bank and Financial Accounts, (“FBARs”) for the years 2007-2011.  ...
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Recent Case Underscores Importance of Delinquent International Information Return Submission Procedures

On February 12, 2018, the IRS assessed $160,000 in penalties against Vivian Ruesch under Internal Revenue Code Section 6038(b) for ...
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Forms 3520 and 3520-A: What You Need to Know

If you own an interest in a foreign trust, you may be required to file Form 3520, Annual Return To ...
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U.S. Income Taxation of U.K. SIPPs and ISAs

Note:  This is the third of three articles on United States income taxation of British Self-Invested Pension Plans (“SIPPs”) and ...
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Illusory Revenue Procedure 2020-17

A self-invested personal pension (“SIPP”) is a highly advantageous personal pension plan available under United Kingdom law.  Separate articles consider ...
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U.S. Income Taxation of Contributions to SIPPs and ISAs

Note:  This is the second of three articles on United States income taxation of Self-Invested Pension Plans (“SIPPs”) and Individual ...
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What Are U.K. SIPPs and ISAs, and How Are they Reported for U.S. Tax Purposes?

Note: This is the first of three articles on United States Income Taxation of British Self-Invested Pension Plans (“SIPPs”) and ...
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Accidental Americans

Hans was born in the United States 43 years ago.  When Hans was 6 years old his parents moved back ...
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Beware Form 3520-A

A U.S. personwho is a beneficiary of a foreign grantor trust must report the trust to the Internal Revenue Service ...
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