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Tag: Usman Mohammad

Recent Developments In FBAR Jurisprudence

By Usman Mohammad and Michael Gelb The CPA Journal, Tax Practice & Procedure Column December 2021 Issue Failing to report foreign bank accounts on a Report of Foreign Bank and Financial Accounts (FBAR) form can carry severe financial consequences. The civil penalty for non-willful violations of the FBAR reporting requirement

Navigating the IRS’s Self-Dealing Rules for Private Foundations

By Usman Mohammad and Emma Westerhof The CPA Journal, Tax Practice & Procedure Column April/May 2021 Issue The Donald J. Trump Foundation was undone by alleged acts of self-dealing involving its namesake, Donald J. Trump, who also allegedly used the foundation to promote his candidacy for president in 2016. The

Reporting Foreign Accounts On The FBAR Versus Form 8938

By Usman Mohammad The CPA Journal August 2020 Edition Because U.S. taxpayers are required to report and pay taxes on their worldwide income, the U.S. government has fought to compel taxpayers to report their interests in overseas bank accounts. In the 1970s, the FBAR (Report of Foreign Bank and Financial Accounts) was created as part of

Foreign Asset Reporting And U.S. Territories

By Usman Mohammad The ABA Tax Times Vol. 39 No. 3 – Spring 2020 Puerto Rico, American Samoa, Guam, The United States Virgin Islands, The Northern Mariana Islands—these are all United States territories or possessions. Individuals born in these territories are deemed by law to be either United States citizens or

Reporting Foreign Retirement Plans On Required Information Returns

By Usman Mohammad The CPA Journal February 2020 Edition Foreign asset reporting—including the reporting of foreign retirement plans—is a high priority for the IRS, which in 2019 listed the “failure to report offshore funds” as one of its “Dirty Dozen Tax Scams,” and has done so for several years running. Individuals

The IRS’s Updated Voluntary Disclosure Procedures For Offshore Accounts And Assets

By: Usman Mohammad The CPA Journal January 2019 Edition On November 20, 2018, the IRS published an Interim Guidance Memo concerning voluntary disclosures, captioned “Updated Voluntary Disclosure Practice” ( The memo sets forth the IRS’s current policy for handling voluntary disclosures (both offshore and domestic) following the closing of the IRS’s