By: Amanda Wilson If you have a foreign bank account (or signatory authority on a foreign bank account), you are required to file a Form 114 (commonly called an FBAR) if at any point during the calendar year the combined balance in all of your...

By: Amanda Wilson In their continued effort to crackdown on offshore activity, the IRS and Treasury released proposed regulations yesterday that target debt held by foreign partnerships. These regulations provide that debt held by foreign...

By: Amanda Wilson If you are a foreign citizen that is considered to be a resident for U.S. income tax purposes, you need to be aware that your U.S. tax filing obligation is not limited to the income tax return. U.S. taxpayers (including foreign...

By: Amanda Wilson As I discussed in a prior blog post (found here), if you have more than $10,000 in a foreign bank account, you are obligated to file Form 114 (commonly known as an FBAR). Failure to make this filing can result in significant civil...