On June 5, 2014, at 2:00 pm (EDT), Matthew D. Lee of Blank Rome LLP, a former Justice Department trial attorney, will present a
webinar addressing federal tax reporting obligations imposed upon U.S. taxpayers with foreign assets. For the past five years, much attention has been focused on offshore bank accounts and the obligation of U.S. taxpayers to report such accounts on the "Report of Foreign Bank and Financial Accounts" or "FBAR" 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. The Treasury Department has recently issued a new FBAR reporting form, now called the FinCEN 114, and now requires that the form be filed electronically each year by June 30.
The Justice Department, working hand-in-hand with the IRS, is currently undertaking an intense, global crackdown on offshore tax evasion by U.S. taxpayers using secret foreign bank accounts. In 2009, the U.S. entered into a landmark agreement with Switzerland’s largest bank, UBS AG, which agreed to pay a record fine to avoid criminal prosecution. The U.S. subsequently prosecuted a number of UBS account holders, bankers, and investment advisors. The U.S. government’s enforcement focus has spread to banks in other countries, such as Israel, India, and many Caribbean countries. Most recently, Credit Suisse, the second largest bank in Switzerland, pleaded guilty to aiding and abetting tax evasion by its U.S. account holders, and agreed to pay an astounding $2.5 billion fine.
Concurrent with the U.S. government's global crackdown on the use of secret foreign bank accounts, the Internal Revenue Service has imposed additional reporting requirements that obligate U.S. taxpayers to annually disclose specified foreign financial assets when they file their personal income tax returns. These new foreign asset reporting rules, which are part of the Foreign Account Tax Compliance Act (FATCA), signal a new era in foreign asset reporting by U.S. taxpayers, and significantly expand the disclosure requirements in scope and type well beyond what was previously required to be reported on the FBAR form.
In addition, the information reporting requirements of FATCA will require foreign banks and financial institutions to annually disclose to the IRS information about their U.S. depositors, and this new law will have significant consequences for non-compliant U.S. taxpayers. FATCA takes effect on July 1, 2014, and
77,000 foreign banks and nearly 70 foreign countries have agreed to participate in this new reporting regime which will provide the U.S. government with a wealth of information regarding the foreign banking activity of U.S. taxpayers.
This webinar will explore the new FATCA foreign asset reporting rules, provide an update on the existing FBAR reporting regime for foreign bank accounts, address the FATCA information reporting requirements for foreign banks, and discuss the U.S. government's enforcement efforts (both criminal and civil) in this area and the likely direction of future enforcement activity.
Webinar: A Brave New World for U.S. Taxpayers with Foreign Assets: Navigating the New and Enhanced FBAR and FATCA Reporting Requirements June 5, 2014 2 pm ET
Register: http://webinars.nsacct.org/session.php?id=13625