The Internal Revenue Service announced in IR-2015-09, Jan. 28, 2015 that avoiding taxes by hiding money or assets in unreported offshore accounts remains on its annual list of tax scams known as the “Dirty Dozen” for the 2015 filing season. "The recent string of successful enforcement actions against offshore tax cheats and the financial organizations that…
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Streamlined OVDP's “Nonwillful Narrative” Requirement.
Taxpayers using either the Streamlined Foreign Offshore Procedures or the Streamlined Domestic Offshore Procedures, will be required to certify, that the failure to report all income, pay all tax and submit all required information returns, including FBARs (FinCEN Form 114, previously Form TD F 90-22,1) was due to Non-Willful Conduct. The IRS's OVDP Strealined Procedures…
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Mexico Issues FATCA Implementation Guidance
The second part of Resolución Miscelánea Fiscal para 2015 was published last week in the official journal and includes an "annex" concerning the rules for implementing an agreement between the Mexican Ministry of Finance (Secretaría de Hacienda y Crédito Público) and the U.S. Treasury Department regarding the FATCA regime. Annex 25 provides guidance on the…
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PLR 201504002 Allows Taxpayer to Reelect the Foreign Earned Income Exclusion
In a Private Letter Ruling (PLR) 201504002, the IRS granted a taxpayer, who has resided outside the U.S. since Year 1, the permission to re-elect the foreign earned income exclusion under Code Sec. 911(a) for Year 4 and subsequent years. Taxpayer is a United States citizen who has resided outside of the United States since…
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