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Gary S. Wolfe, Esq. - ArticlesGary S. Wolfe is an international tax attorney specializing in asset protection, IRS tax audits and international litigation. Please see http://gswlaw.com for more information.
Penalty Regime for Foreign Bank Account Filing (FBAR)Each U.S. person who has a financial interest in, or signature or other authority over, one or more foreign financial accounts (valued over $10,000, at any time during a calendar year) is required to report the account on Schedule B/Form 1040, and TD F 90-22.1 (Report of Foreign Bank and Financial Accounts (FBAR)), due by June 30 of the succeeding year. FBAR - U.S. TAXPAYER REPORT OF FOREIGN BANK & FINANCIAL ACCOUNTS - FORM TD F 90-22.1Form TD F 90.22-1 is required to be filed by every U.S. person for each calendar year in which such person has a financial interest in, or signature or other authority over, any foreign financial accounts with an aggregate value exceeding $10,000 at any time during the calendar year. Casualty (Theft) LossSection 165 of the Internal Revenue Code of 1954 provides for the deduction of losses arising from theft. The term Theft . . . converting any criminal appropriation of another’s property to the use of the taker, particularly including theft by swindling, false pretenses, and any other form of guile. EB-5 Investor Visa (U.S. Tax Issues)A Federal program known as EB-5 (Immigrant-Investor Visa), administered by the U.S. Citizenship & Immigration Services (“USCIS”), encourages foreign investors to invest their way to living in the U.S.A. Summary of E-2 VisaThis type of Visa will be particularly valuable for foreign nationals who wish to visit the United States for up to 122 days per year (less than 183 days in any one year), and who do not require a Green Card (in order to avoid U.S. income taxation on their world-wide income). The E-2 Visa is particularly suited for international investors who would like a second home in the U.S. The IRS & Madoff Investors: "Theft Losses" (Ponzi Schemes)On 3/17/09, IRS Commissioner Doug Shulman told the Senate Finance Committee:
". . . Thousands of Taxpayers have been victimized by dozens of fraudulent investment schemes. These too-good-to-be-true investment uses have often taken the form of so-called "Ponzi schemes" (i.e., the fraud perpetrator promises investments returns, some or all of which are fictitious)... International Tax Compliance - Foreign PartnershipsAny U.S. Person who controls a foreign partnership during the tax year must file a Form 8865 (for a partnership). (IRC §6038.) This form must be filed with the U.S. Person's timely filed federal tax return (including extensions). Tax Payers, Tax Preparers And Unreported IncomeRecent Senate reports reveal $100 billion dollars a year not being paid in US taxes for assets held offshore by US taxpayers. The following is a summary of penalties and fines for Tax Payers and Tax Preparers re: unreported income. Irs Tax Audits – By The NumbersWhile the IRS is aggressively pursuing taxes overseas, domestically they have been increasing audits for individuals, higher-income taxpayers, as well as the business returns of S-corporations and Partnerships: International Tax Compliance - Foreign CorporationsAny U.S. Person who controls a foreign corporation or foreign partnership during the tax year must file a Form 5471 (for a corporation). (IRC §6038.) This form must be filed with the U.S. Person's timely filed federal tax return (including extensions).
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