IRS Amnesty, FATCA & FFI Reporting

1.0 CLE Credit
Certification Credits: International Law
Total presentation time:
Level: Intermediate

download as pdf


1. The Foreign Account Tax Compliance Act (FATCA): Americans now required to disclose all foreign financial assets
Read article online

2. Foreign Financial Institutions: Reporting and Withholding United States Taxes
Read article online

3. New Amnesty Program for Unreported Foreign Income
Read article online



Veteran South Florida Tax Attorney
Richard S. Lehman will explain:

The I.R.S. New Amnesty Program

  • Beginning taxable year 2012
  • The tax wake up call for Americans with unreported assets and/or income

Foreign Account Tax Compliance Act (FATCA)

  • Beginning taxable year 2011
  • U.S. Voluntary Disclosures
  • All Foreign Financial Assets Reported

Institutional Foreign Financial Reporting

  • Preparations necessary in 2013
  • All Foreign Financial Institutions Complete Reporting all U.S. Accounts
  • Foreign Financial Institution to Withhold Tax on all U.S. Accounts Thirty (30%) Percent of Gross Income

TESTIMONIAL: Richard Lehman is among the most knowledgable practitioners in the field of international tax law, and presented a concise, factual analysis of what FACTA will mean for taxpayers. . . Tax Manager, Wilmington, DE.


United States Treasury Decision 9567: IRS Temporary Regulations on reporting of specified foreign financial assets.

Instructions for Form 8930: Statement of Specified Foreign Financial Assets.

The New Treaty and Annex: download pdf -31 pages includes:

  • Model Intergovernmental Agreement to Improve Tax Compliance and to Implement FATCA
  • ANNEX 1: Due diligence obligations for identifying and reporting on U.S. Reportable accounts and on payments to certain non participating financial institutions
  • ANNEX 2: Non-reporting [FATCA Partner] Financial Institutions and Products

IRS “Amnesty” Questions:

TESTIMONIAL: I enjoyed the course and found it to be very helpful.
CPA/Public Accountant, Shreveport, LA.

TESTIMONIAL: A most rewarding presentation that I have attended in a long while. . .
OWNER/SOLE PROPRIETOR, Registered Tax Return Preparer, Waterfront, DC

What America does not know is the Internal Revenue System (I.R.S.) now has all of the tools necessary to find an American’s assets and sources of income.

Two pieces of Tax Legislation have been phased in over the last few years. Those two pieces of legislation, together with existing law, now make sure that every United States taxpayer’s assets and source of income, both foreign and domestic, will be included in an information return or a tax return that must be filed with the Internal Revenue Service of the United States.

These two new laws require U.S. Taxpayers to report all of their interest in foreign assets and shortly will require every foreign financial institution and many foreign non financial entities to report all payments to U.S. Taxpayers or the foreign institution will have to pay that tax.

The IRS will be looking for offshore unreported income. Several thousand new agents have just been approved. The penalties, fines and taxes that can result from unreported foreign income could be life ruining.

The I.R.S. has provided an open ended Amnesty Program for unreported income and unreported foreign accounts.

The Amnesty Program must be handled by professionals who know what they are doing. There are legal safeguards and different levels of payments and taxes. There is a one time payment on unreported bank deposits that can be assessed at penalties ranging from 0% to 27.5% of the deposit. This program can be terminated at any time by the Internal Revenue Service.

This informative 1-hour seminar includes important topics of discussion such as:

Latest development with tax treaties for FFI Reporting purposes, the cost of the Amnesty, required information, penalties, payment, proper documents, specified foreign financial asset, the minimum reporting requirements, helpful definitions, other financial assets, exclusions for assets not subject to reporting, valuation guidelines and more.


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