Exercising broad regulatory authority, US Treasury has clarified the meaning of “resident” for #FBAR Purposes

Introduction – Looking For Mr. FBAR Attention – as a U.S. Citizen your primary obligation of U.S. citizenship is to: "Report Early! Report Often! Report Everything! Keep a record of what you report!" @VlJeker and @Expatriationlaw go "Looking For Mr. #FBAR": https://t.co/94AXVYZkRl — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) February 8, 2020 […]

Like FBAR, Form 8938, Form 3520 and Form 5471 – Canada has its own foreign asset reporting rules

Prologue Last week I received a call from one of the many Americans abroad living (not hiding out) in Canada. He did NOT know about his U.S. tax obligations. Therefore, he has not been filing U.S. taxes. Interestingly, he had a portfolio of U.S. stocks (foreign to Canada) which were providing him with a consistent […]

When a US citizen marries a non-citizen – AKA The #FBAR Marriage: Filing status, joint ownership of assets, income, gift and estate tax issues

Thanks to @VlJeker for participating in this video series. Again, the most important question of our age is: "Is it the U.S. citizen or is it the non-citizen that is the source of the problem in the #FBARMarriage?" Your thoughts? https://t.co/SiPJAY4alz — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) February 7, 2019 Marriage […]

Mr. Bedrosian (a pioneer in FBAR history) meets Mr. #FBAR: The good, the bad and the ugly

Why the Arthur Bedrosian meeting with Mr. FBAR is important Synopsis: The Bedrosian FBAR case is an incredibly important victory for taxpayers. Judge Baylson first ruled that FBAR “willfulness” in the “civil” context did NOT require knowledge that filing an FBAR was a legal duty (the criminal standard). He then ruled that Mr. Bedrosian’s failure […]

U.S. "culture of penalty" and inflation: First, inflation used to increase the size of #FBAR penalty base and then to increase the size of actual penalties

Introduction: Penalty as a part of American Culture "U.S. tax, form and penalty club": Google "IRS penalty as part of American culture" and see a wide range of results https://t.co/eR0QTZ2sOH — Citizenship Lawyer (@ExpatriationLaw) June 25, 2017 The above tweet links to a wide range of examples of America’s culture of penalty. The purpose of […]

Mr. Pomerantz meets Mr. #FBAR in the Homeland: The "willful" FBAR penalty requires proof of "willfulness"

Looking for Mr. FBAR This is one more in a series of posts discussing the FBAR rules. The FBAR rules were born in 1970, laid virtually dormant until the 2000s and then were then unleashed in their full “ferocity” on U.S. persons. A good review of the history of Mr. FBAR is here. A discussion […]

Did Mr. #FBAR really pay a surprise visit to Canada?

Update June 19, 2017: The Department of Justice sued Mr. Pomerantz in Seattle. The purpose of the lawsuit was to get a judgment against Mr. Pomerantz. Interestingly, the Government lost the lawsuit for reasons unrelated to the substance of the issue. The Government failed to plead the facts that it needed to succeed in the […]

Part 2: Be careful what you "Fix For" – Mr. Kentera meets Mr. #FBAR in the "Twilight Zone"

Introduction … Most meetings with Mr. #FBAR take place in "The Twilight Zone" https://t.co/9UJw0GxGIf pic.twitter.com/uqjqYsKKtZ — Citizenship Lawyer (@ExpatriationLaw) February 5, 2017 This post is one more of a collection of FBAR posts on this blog. The most recent FBAR posts are here and here. The “unfiled FBAR” continues to be a problem for certain […]

Be careful what you "fix for"! A Holiday Gift: What to do about the unfiled #FBAR

As 2016 comes to an end … Received #greatholidaynews today from two "ecstatic" renunciants who confirm that the wait time for CLNs is down to 2 – 3 months in Canada! — Citizenship Lawyer (@ExpatriationLaw) December 17, 2016 I suspect that history will show that that the growth in renunciations of U.S. citizenship (and abandonment […]