Firm News

Your starting point should be form 8938 which covers all foreign assets including everything which would be included on this June's FBARs. The 8938 has a part that deals with interests in foreign financial institutions and there is a part which deals with "everything...

I recently spent a week on a FATCA exploratory journey visiting with bankers, CPA’s, attorneys and American ex patriots in Panama. Despite the bad press America has been getting all over the world today for a variety of reasons, Panama is one place on the planet where...

How You Could Increase Your Chance Of An Audit When You File This Year's New Form 8938, Statement of Foreign Assets There is a new wrinkle this year on required disclosure of foreign assets. The general rule used to be that “taxable events” during the past year...

With the publication on February 8, 2012 of the FATCA bank withholding regulations, it is clear that the FATCA train has left the station.  The 400 pages of new Regulations would apply to almost every non-American bank in the world if they wish to continue to do...

We found a very interesting blog titled The Isaac Brock Society.  “The Isaac Brock Society consists of individuals who are concerned about the treatment by the United States government of US persons who live in Canada and abroad.”  I saw a post that caught my...

For all the groaning about FATCA, there is one “red herring” which should be given the lie right away, and that is the silly notion that FATCA is an attempt to force the application of U.S. law on foreign financial institutions.  In fact it does nothing of the sort....

Professor Dick Harvey, Jr. has given us a wonderful article on the withholding issues of FATCA. We learn the enforcement buzz word/issue of the new century:   will  compliance-challenged  (Dick calls them “tax cheats”) US taxpayers continue to beat the system by moving their foreign accounts to foreign banks which don’t care if they can’t sell US securities. They may decide…

WHAT HAPPENS TO ALL THE AMERICAN TAXPAYERS WHO CONTINUE TO HOLD OFFSHORE ACCOUNTS? As the IRS keeps up the pressure on U.S. taxpayers who are using offshore financial accounts and foreign investments to avoid U.S. taxes, many people who have been losing sleep over what to do about their foreign accounts  and  real estate  in Panama,  Belize and elsewhere, are…

Almost thirteen years ago, the IRS “reinvented” itself with a massive reorganization which changed the IRS corporate culture and the way the IRS had been doing business since 1952. Before 1998, the IRS was organized by geographical districts and regions which were virtual fiefdoms where district directors ruled over chiefs of collection, examination, and criminal investigations.  In the 1998 Reorganization,…