For much of the past decade, the Internal Revenue Service has focused significant attention on offshore bank accounts and the obligation of U.S. taxpayers to report such accounts on the FBAR (Report of Foreign Bank and Financial Accounts) form. The FBAR rules require taxpayers to annually report whether they have a financial interest in, or signature or other authority over, foreign bank accounts, and impose substantial civil and criminal penalties for failing to do so. In addition, the Foreign Account Tax Compliance Act (FATCA) now requires individuals and certain entities to annually disclose specified foreign financial assets on Form 8938. The information reporting requirements of FATCA also require foreign banks and financial institutions to annually disclose to the IRS information about their U.S. customers.The IRS now has access to far more information regarding the offshore activities of U.S. taxpayers than ever, and non-compliant U.S. taxpayers face significant risks.
Webinar attendees will review the FBAR reporting regime for foreign bank accounts, explore the relatively new FATCA foreign asset reporting rules, learn of IRS enforcement efforts in this area, and study options for curing non-compliance.
Fox Rothschild LLP
Partner
[email protected]
(215) 299-2765
Matthew D. Lee is a partner at the law firm of Fox Rothschild LLP in Philadelphia. He is co-chair of the firm's White-Collar Criminal Defense & Regulatory Compliance practice group and maintains an extensive tax controversy practice. Mr. Lee regularly represents individuals and businesses in criminal and civil tax matters, including criminal tax investigations, prosecutions, and proceedings before the Internal Revenue Service, such as audits, appeals, and collection matters.
Blank Rome LLP
Associate Tax Attorney
[email protected]
(215) 569-5752
Jeffrey Rosenfeld concentrates his practice in the area of business tax law. He counsels public and private corporations, partnerships, and individuals in a broad array of tax matters including: