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2011 Report of Foreign Bank and Financial Accounts ("FBAR") due June 30

Morrison & Foerster LLP
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USA
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June 13 2012

We wanted to remind our clients that Treasury Form TD F-90 22.1 “Report of Foreign Bank and Financial Accounts” (commonly known as the “FBAR”) is due on June 30, 2012 with respect to the calendar year 2011

Reasserting its role as final interpreter of the law, the Supreme Court rejects irs "fighting regulation" in United States v. Home Concrete & Supply, LLC, et al.

Morrison & Foerster LLP
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USA
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May 4 2012

On April 25, 2012, the Supreme Court issued a 5-4 opinion, written by Justice Breyer, concluding that Treasury Regulation 301.6501(e)-1(a)(iii) was invalid

IRS offshore voluntary discosure program reopens

Morrison & Foerster LLP
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USA
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January 10 2012

On January 9, 2012, the Internal Revenue Service (the “IRS”) reopened indefinitely its offshore voluntary disclosure program (the “2012 OVDP”) to assist taxpayers in reporting undisclosed foreign accounts, assets, and income

FinCEN and IRS extend certain FBAR filing deadlines

Morrison & Foerster LLP
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USA
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June 20 2011

During the past few weeks, the Financial Crimes Enforcement Network (“FinCEN”) and the Internal Revenue Service (“IRS”) released three notices affecting the filing of Form TD F 90-22.1 “Report of Foreign Bank and Financial Accounts” (“FBAR”), which are discussed below

Expanded whistleblower regulations, schedule UTP and corporate governance: a potent combination of IRS strategies

Morrison & Foerster LLP
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USA
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February 17 2011

The Internal Revenue Service's interest in encouraging and incentivizing whistleblowers appears unlikely to subside

IRS unveils 2011 Offshore Voluntary Disclosure Initiative

Morrison & Foerster LLP
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USA
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February 14 2011

On February 8, 2011, the IRS unveiled the 2011 Offshore Voluntary Disclosure Initiative ("OVDI"), pursuant to which taxpayers may come forward, through August 31, 2011, to report previously undisclosed foreign accounts, assets, and income

IRS considers new partial amnesty program for offshore accounts: strategic considerations for taxpayers

Morrison & Foerster LLP
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USA
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January 26 2011

Taxpayers who hold any interest in, or signature authority over, a foreign bank account are required to indicate that on Schedule B of the Form 1040, and also file with the Treasury a Report of Foreign Bank and Financial Accounts, Form TD F 90-22

Schedule UTP: the IRS's most aggressive tax position to date

Morrison & Foerster LLP
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USA
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October 6 2010

On September 24, 2010, the Internal Revenue Service released the anxiously anticipated final version of Schedule UTP (Uncertain Tax Positions) and associated instructions

Small Business Jobs Act of 2010 key revenue-raising provisions

Morrison & Foerster LLP
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USA
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October 1 2010

As discussed in our prior client alert, President Obama signed into law the Small Business Jobs Act of 2010 (H.R. 5297, the “Act”) on September 27, 2010

IRS releases proposed UTP regulations

Morrison & Foerster LLP
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USA
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September 14 2010

On September 8, 2010, the IRS released proposed regulations 1.6012-2(a)(4)-(5) which require certain business taxpayers to attach the Schedule UTP, Uncertain Tax Position Statement, to their income tax returns effective for tax years beginning after December 15, 2009 and ending after the date of publication of the final regulations

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