Foreign Asset Reporting

Late QEF Election Granted to Married Couple Unaware of PFIC Status (PLR 202220014, February 2, 2022)

Taxpayers filed their U.S. federal income tax returns as a married couple filing jointly for the 5 years relevant to this letter ruling....

2022 Update to the Form 14457, Voluntary Disclosure Practice Preclearance Request

On February 15, 2022, the IRS announced an update to the Form 14457, 'Voluntary Disclosure Practice Preclearance Request'. Noncompliance...

Options for Noncompliance with US Foreign Reporting Obligations

Noncompliance with foreign reporting obligations such as the FBAR and the Form 8938 ‘Statement of Foreign Financial Assets’ can result in...

Penalties for Non-willful Violations of FBAR Filings must be Assessed on a Per Form Basis

Kaufmann had 13 foreign accounts in Israel that were not reported on the Form TD F 90-22.1, "Report of Foreign Bank and Financial...

Don't Forget to Report Foreign Gifts and Inheritances

Gifting can be a great way to move appreciated assets out of your estate, transfer income to lower taxed family members or just to be...