Offshore Voluntary Disclosure Program

Offshore Voluntary Disclosure Program

This final installment of this blog series will discuss taxpayers who willfully have not disclosed foreign accounts or paid taxes. Taxpayers who want assurance that they will not be subject to criminal liability and/or substantial monetary penalties should consider...
Streamlined Filing Compliance Procedures

Streamlined Filing Compliance Procedures

In this International Tax Blog series we have been discussing the implications of failing to disclose foreign accounts to the U.S. government. The required form to disclose foreign accounts is FinCEN 114, Report of Foreign Bank and Financial Accounts, commonly...

Expatriation – The Disillusioned Part II

Last week we began the story of John and Jane Farkle, U.S. citizens who had decided to expatriate (i.e., renounce their U.S. citizenship) after becoming disillusioned with the U.S. political climate. Unfortunately, the more they learned about the expatriation process...