In Rafizadeh v. Commissioner, 150 T.C. No. 1, the Tax Court issued an important decision for the taxpayers, holding that the six-year statute of limitations with respect to income attributable to certain “specified foreign financial assets”, is effective only for those tax years to which the reporting requirement was applicable and in effect.
Three Orange County, California residents were sentenced to prison today for willfully failing to file Foreign Bank Account Reports (FBAR), disclosing their secret accounts in Switzerland and Israel.
Beginning this year, reporting for the 2016 calendar year, the due date for filing Foreign Bank Account Reports (FBAR) changes from June 30th (which applied to all the previous tax years) to the same filing deadline as individual income tax returns, April 15.
According to the new data, 55,800 taxpayers have come into the Offshore Voluntary Disclosure Program (OVDP) to resolve their tax obligations, paying more than $9.9 billion in taxes, interest and penalties since 2009.
Showing that the IRS fight against secret offshore bank accounts is truly global, the Department of Justice and the Internal Revenue Service are trying to force a Singapore bank to disclose its information about an account held by a U.S. citizen residing in China.
In order to effectively implement FATCA requirements, the United States have worked with foreign governments to develop two types of Intergovernmental Agreements (IGAs).