Potentially significant ruling seen, as U.S. appeals court finds 'non-willful penalty' should apply 'per FBAR'

In the latest in a series of cases that experts say has potentially major repercussions for expatriate Americans, a U.S. District Court in California has ruled that the penalty for a so-called "non-willful" failure to file foreign bank account reports (FBARs) should be calculated on a "per-FBAR", annual form basis, rather than for each bank account held by the American taxpayer in question outside the U.S.

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Questions being asked, after info request revelations of Canadian FATCA transfer data

American expats and spokespeople for organizations representing them have been asking questions about the scale of U.S. expat data being forwarded to the U.S. under the Foreign Account Tax Compliance Act, after the latest Canadian Revenue Agency (CRA) report of such data revealed that around two thirds of the accounts sent actually fell below the US$50,000 FATCA reporting minimum threshold

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Opinion

SEAT reminder: 'April 7 is deadline for you to tell Senate Finance C'ttee how well U.S. int'l tax regime works for you'

SEAT reminder: 'April 7 is deadline for you to tell Senate Finance C'ttee how well U.S. int'l tax regime works for you'

As we reported here last week, the U.S. Senate Finance Committee held a hearing last month on “How U.S. International Tax Policy Impacts American Workers, Jobs, and Investment." Many in...

Apr-06-2021