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MODIFICATIONS

We may modify these Terms at any time without notice to you. The latest Terms will be posted on our Website. By using the website after we have posted modifications, you agree to be bound by the modifications. If you do not accept the Terms as modified, do not continue to use the Website.

LIMITED LICENSE

We grant you a limited, non-exclusive, non-transferable, revocable license, without any right to sublicense, to use our Website strictly in accordance with the Terms. You may use the Website solely for personal, non-commercial purposes, and not for republication, distribution, assignment, sublicense, sale, preparation of derivative works, or any other use. Commercial use of any content on the Website is absolutely forbidden. You may not print out or use an electronic version of any part of our Website. You agree not to copy materials, content or any other information on the Website, reverse engineer or break into (hack) the Website, or use materials, products or services in violation of any state or federal law.

LAWFUL USE

You agree to comply with all applicable domestic and international laws, statutes, ordinances and regulations regarding your use of our Website. In addition, you agree not to manipulate or otherwise display the Website by using framing or similar navigational technology. You agree not to access the Website by any means other than through the standard industry-accepted interfaces. You will not use the Website for any purpose that is unlawful or prohibited by these Terms. You may not use the Website in any manner which could damage, disable, interrupt, over burden, or impair the Website or WLIM’s network or servers, or interfere with any other party’s use and enjoyment of the Website. You may not attempt to gain unauthorized access to the Website, other accounts, computer systems or networks connected to the Website, through hacking, password mining or any other means. You may not obtain or attempt to obtain any materials or information through any means not intentionally made available through the Website. In addition, you shall not register, subscribe, attempt to register, attempt to subscribe, unsubscribe, or attempt to unsubscribe, any party for the Website if you are not expressly authorized by such party to do so.

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OUR INTELLECTUAL PROPERTY

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INTENDED AUDIENCE

This Website is intended for adults aged 18 years or older. Any registration by, use of or access to our Website by anyone under age 18, is unauthorized, unlicensed and in violation of these Terms of Use. By using our Website you represent and warrant that you are 18 or older and that you agree to and to abide by all of the terms and conditions of this Agreement.

[WLIM has sole right and discretion to determine whether to accept a Client, and may reject a Client with or without explanation.

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You agree to immediately notify us of any unauthorized use of your password or any other breach of security. You agree that our Website cannot and will not be liable for any loss or damage arising from your failure to comply with password security as discussed herein.]

FINANCIAL, LEGAL AND OTHER ADVICE DISCLAIMER

Your use of the Website creates no professional relationship of any kind between you and WLIM. Nothing contained in our Website shall constitute financial, investment, legal and/or other professional advice to or for you. You hereby agree that you shall not make any financial, investment, legal and/or other decision based in whole or in part on anything contained in our Website.

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Without limitation, we will have exclusive ownership of all present and future existing rights to the Submission of every kind and nature everywhere. We will be entitled to use the Submission for any commercial or other purpose whatsoever, without compensation to you or any other person sending the Submission. You acknowledge that you are responsible for whatever material you submit, and you, not us, have full responsibility for the message, including its legality, reliability, appropriateness, originality, and copyright.

We may assign these Terms and our rights hereunder, in whole or in part, to a third party, in our sole discretion, in connection with a merger, acquisition, reorganization or sale of substantially all of our assets, or otherwise. You may not assign, sublicense, or delegate any of your rights hereunder.

PRIVACY POLICY

Our Privacy Policy is considered part of this Agreement. You should review this Privacy Policy by clicking on this link.

Changes Coming to US Expats' FBAR/FINCEN Filing Experience

Read the text from the article below. To read the PDF, click here.


Attention American expat and US taxpayers with non-US financial accounts: changes are on the horizon for your 2016 FBAR filing, including a new April 15 due date.

Also likely coming your way: an automatic June 15 extension date with a possible additional extension option until Oct. 15. More on this below.

Additionally, the IRS will have the ability to waive penalties for taxpayers who file their first required FinCEN 114 form.

The changes are embedded in this piece of legislation, in section 2006.

Here’s a bit of background: Americans with non-US financial accounts are required to provide substantial information each year to the US Department of the Treasury, including a Foreign Bank Account Report (FBAR), which is now known as the FinCEN 114.

The small changes in FinCEN 114 reporting became law on July 31 and still aren’t widely known by those who are affected.

For tax years after Dec 31, 2015, the FinCEN 114 will now be due ton April 15 and certain filers will be allowed an extension until Oct 15. Before the new law was passed, the FinCEN 114 was due on June 30, with no possibility of extending. While the new law isn’t explicit, the language implies that filers would get an automatic June 15 extension.

Right now, overseas taxpayers get automatic extensions from April 15 to June 15 for filing personal tax returns and often have to file to extend to Oct 15 or Dec 15 because of the complexities of complying with tax requirements in their countries of residence as well as the US.

Therefore, with this change, the FinCEN 114 takes another step closer to being treated like an ordinary tax form. Perhaps it’ll eventually be combined with the Foreign Account Tax Compliance Act (FATCA) form 8938; a suggestion made by the Taxpayer Advocate and several overseas American organizations.

A number of American expats and non-Americans living in the US, have been critical of the FBAR/FinCEN 114 form for the following reasons:

  • The forms require highly detailed information about foreign financial accounts, including account numbers, bank names and addresses, as well as highest balance, which, in the wrong hands, can lead to identity theft, theft of cash, or worse.

  • Penalties for failure to file these forms can in theory exceed 300% of the highest account balance.

  • Some US expats and dual nationals who have financial accounts in the country where they live don’t consider their accounts as “foreign” and would support a Same Country Exception. Here’s my recent commentary (http://blogs.wsj.com/expat/2015/07/28/fatca-relief-coming-for-u-s-expats-via-same-country-exception-opinion/) on the topic.

  • Americans with authority over an employer’s bank accounts in a foreign country may have to report these accounts on their personal FinCEN 114.

  • Americans who have financial or other authority over a family member’s financial accounts in a foreign country (e.g. an aging parent, a special needs child) also have a reporting requirement, which represents an additional burden considering they have no financial interest in the accounts.

  • When the Treasury Department starting allowing and then requiring electronic filing of the FinCEN 114 here (http://bsaefiling.fincen.treas.gov/NoRegFBARFiler.html), it directed taxpayers to the Financial Crimes Enforcement Network to make their filing, which intimidated and angered some filers.

Addressing these plus bigger structural issues affecting US expats (for example, shifting to residency-based taxation from citizenship-based taxation and changing or repealing FATCA) are on my and others’ wish lists. But today we can take some small comfort that members. ofCongress and Treasury are becoming aware of the issues and starting to make changes that could make compliance with tax laws a bit easier.

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