Texas Court rules 'non-willful penalty' should apply 'per FBAR' not per account

In a case experts say has potentially major repercussions for expatriate Americans, the U.S. District Court for the Eastern District of Texas has ruled that the penalty for so-called "non-willful violations" of the U.S. Foreign Bank Account Reporting regulations should be calculated on a "per-FBAR", rather than per account, basis.

  • Tax

'Dangerous liaisons': Foreign assets and their U.S. taxpayer nominees

For various reasons, people, including those with U.S. tax obligations,  have long taken advantage of the option to use so-called "nominees" to hold legal title to some of their non-U.S. assets. But while there can be arguably good reasons for doing so, especially in countries where Shariah Law can dictate how assets are distributed when someone dies, it can also result in huge and unexpected problems.

Here, in an excerpt from her most recent blog, Dubai-based tax expert Virginia La Torre Jeker considers some of the issues that can arise.

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Opinion

Tax Foundation: Joe Biden’s plan to address 'offshoring' comes with contradictions 

Tax Foundation: Joe Biden’s plan to address 'offshoring' comes with contradictions 

Last week, American voters – and business executives, onshore and abroad – finally got a look at Democratic presidential candidate Joe Biden's thoughts about how he planned to change the...

Sep-16-2020