The IRS recently issued Notice 2017-10 addressing flaws in what are known as "syndicated conservation easements." The IRS has stressed that legitimate conservation easements (when the owner of land gets a tax deduction for donating use of the land is for a protected purpose such as wildlife or wetland preservation, grazing, historical importance, etc.) are not meant to be impacted by this Notice.
FBAR penalties, part 2: When is noncompliance considered willful?
Let's resume our discussion about penalties for failure to properly report offshore assets.
Penalties for failure to file an FBAR, part 1: a case example
Swiss firms continue to feel offshore compliance pressure
Troubles continue for Swiss banks dealing with the long-running enforcement campaign by U.S. authorities on offshore account reporting.
By the numbers: offshore disclosure programs rake in the revenue
Last month, we devoted a two-part post to the added pressure to disclose offshore accounts caused by the implementation of the Foreign Account Tax Compliance Act (FATCA).
FATCA as an offshore game changer, part 2: many choose to enter OVDP
In the first part of this post last week, we noted the Treasury Department's postponement of some of the withholding requirements that the Foreign Account Tax Compliance Act (FATCA) will require of foreign banks on accounts held by U.S. taxpayers.
FATCA as an offshore game changer, part 1: withholding by foreign banks
Delays in implementing the Foreign Account Tax Compliance Act (FATCA) are nothing new. Writing about such delays today, the day after famed phrasemaker Yogi Berra died, one could rightly say that it's déjà vu all over again.
IRS again uses John Doe summons to seek offshore account identities
This is a follow-up to the post we did a week ago on the IRS's use of a procedure called a John Doe summons to seek information about undisclosed offshore accounts.
What is a John Doe summons and why is it used?
The IRS defines a John Doe summons as a summons directed against a taxpayer who is under investigation but whose name is not known. Such a summons can also be directed against a group of unidentified taxpayers.
Two weeks until deadline to disclose foreign accounts
It’s that time of year again for a reminder blog about FBAR, Form 114, Report of Foreign Bank and Financial Accounts filing requirements. The filing deadline is June 30 and there are no extensions.
