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News, Articles & Resources

Category: International Tax

Split Among Federal Circuit Courts on the Application of the “Non-Willful” FBAR Penalty

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Any individual that has direct ownership, signatory authority or beneficial ownership over a foreign bank account that has a balance of $10,000 during any point of the year is required to file a Report of Foreign Bank and Financial Accounts (“FBAR”).  The penalties for failing to file an FBAR can…

Million-Dollar Penalty Upheld for Failing to Disclose Foreign Financial Assets

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In 2002, Letantia Bussell was criminally charged with concealing financial assets in offshore accounts.  Bussell was required to disclose her financial interest in an overseas account which she had to report in 2007 by filing a Report of Foreign Bank and Foreign Accounts (“FBAR”).  She failed to make the required…

Service Announces Pending Closure of Offshore Voluntary Disclosure Program

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IR-2018-53 On March 13, 2018, the Service issued IR-2018-52, announcing its intention to close the Offshore Voluntary Disclosure Program (“OVDP”) effective September 28, 2018.  The Service’s stated intention for the issuance of IR-2018-52 is to allow United States taxpayers with undisclosed foreign accounts to use the OVDP before the program…

The Tax Consequences of Expatriation

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K&D shareholder Patrick J. McCormick authored “The Tax Consequences of Expatriation”, appearing in the November 2017 issue of the Journal of Taxation and the January 2018 Journal of International Taxation as their cover article.  Mr. McCormick specializes in all areas of international taxation, regularly assisting clients with all aspects of…

International Reporting Failures Create Penalty and Statute of Limitations Problems

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An ever-growing number of businesses and individuals are going global. Familiarity with the U.S. tax forms that are necessary to properly disclose foreign assets and interests is thus paramount. Four critical forms – Foreign Bank Accounting Re-port (FBAR), 8938, 8621, and 3520 – are summarized, including applicable penalties. READ MORE…

FBAR Penalty Assessment and Enforcement

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K&D associate, Patrick J. McCormick, authored the below article, “FBAR Penalty Assessment and Enforcement“. This article, published here with permission, will appear in the July 2017 issue of the Journal of International Taxation (Thomson Reuters/Checkpoint). Mr. McCormick specializes in the areas of international tax and tax compliance. Introduction CLICK TO…

Key Estate Planning Concepts for International Clients

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K&D associate, Patrick J. McCormick, authored the below article, “Key Estate Planning Concepts for International Clients”, which will appear in the forthcoming June 2017 issue of Estate Planning, a nationally recognized journal published by Thomson Reuters, and again in a Summer 2017 issue of the Journal of International Taxation, also published…

Tax Reporting Implications of Foreign Mutual Funds

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Due to the increased prevalence of foreign mutual funds, tax practitioners should be familiar with the related reporting requirements. Patrick J. McCormick authored the below article in the September issue of Practical Tax Strategies, a national tax journal published by Thomson Reuters (and distributed electronically through RIA Checkpoint).  The following article has…

International Taxation: Common Forms, Requirements, and Hazards

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INTRODUCTION International tax is a rapidly expanding area, no longer an esoteric topic exclusively relevant to multinational corporations. As a result of expanding globalization, more and more clients maintain international ties, whether through dual citizenship, having previously worked overseas, or from having family members in other countries. Increased emphasis on…

OVDP or Streamlined: Choosing an Offshore Disclosure Program

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Patrick McCormick published a featured article in the July 11, 2016 edition of Tax Notes International, the most-cited international tax journal in the United States.  The article, republished with permission from Tax Notes International, can be downloaded in PDF format using the link below. Click Here to download the full article! Patrick McCormick is…

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