Back in April of 2016, I predicted that the Panama Papers leak would eventually lead to the U.S. Treasury Department and Internal Revenue Service (IRS) modifying the offshore disclosure programs in effect today [Fn1]. The leak from Panama Papers law firm Mossack Fonesca basically gives an offshore asset roadmap to the IRS and it is a good bet that the U.S. Government either has or will soon obtain a copy of the documents.
AS most tax professionals working with international assets know, the U.S. has very harsh offshore disclosure requirements. The Foreign Bank Account Report (FBAR) requires reporting of all foreign bank accounts over $10,000 in aggregate value. FBAR requirements have existed since the 1980s. More recently, Congress implemented the Foreign Account Tax Compliance Act (FATCA) which requires a myriad of disclosures for various foreign assets. Penalties for merely failing to file can be draconian.
Insights and Analysis
By now, anyone who follows international finance, tax, or law has heard about the ICIJ reporting on the leak of over 11 million documents from Panamanian law firm Mossack Fonesca. According to the news reporting, the documents contain a vast amount of information on offshore assets and shell corporations used by the rich and famous to ... [Read more]
The stars seem to be aligned for a massive shift in the way offshore assets are held and accounted for. The recent leak to the ICIJ media consortium of the Panama Papers, 2.6 Terabytes of information on the offshore holdings of many prominent and wealthy individuals, certainly marks an expansion in the ever growing program to ... [Read more]