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Tripping Over the Tax Goal Line

International|Tax

By PJ Rogers

Soccer made recent headlines in the U.S. Unfortunately, it wasn’t due to resurging Premier League great Manchester United, speculation of the upcoming matchup between respective German and Italian powerhouses Bayern Munich and Juventus, or another Christiano Ronaldo wonder goal.  In December 2014, FIFA chose not to release the results of an internal investigation into corruption.  The report’s independent author, American lawyer Michael Garcia, resigned in protest.  However, this would not be the end.  Fast-forward to May 14, 2015, and the controversy surrounding FIFA, the world’s soccer governing body, erupts into one of history’s most prominent corruption scandals with the indictment of 14 governing FIFA officials.  Charges continue to flow out of the Department of Justice (DOJ) - this time, alleging over $200 million in bribes and kickbacks.  On December 4, the DOJ released 16 new indictments, focusing on officials from the FIFA subsidiaries in charge of the North and South American World Cup qualifying matches.  

The additional 16 defendants are charged with racketeering, wire fraud, money- laundering conspiracies, and tax evasion and tax fraud in a 92-count indictment.  The alleged 16 defendants received over $200 million dollars in bribes and kickbacks for lucrative media and marketing rights to the 2014 World Cup in Brazil.  The FBI traced money through U.S. banks, allowing the FBI to argue that the conspiracies were planned in the United States, giving jurisdiction to the DOJ anywhere, even if the defendants were in other countries. 

The tax charges also include Failure to File a Report of Foreign Bank and Financial Accounts, which come with civil penalties of the greater of $100,000 or 50% of the balance in an unreported foreign account, per year.  The U.S. Treasury Department requires the filing of an FBAR if you meet any of the following requirements: 

A U.S. person with financial interests in or signature authority over foreign financial accounts generally must file Fin CEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR) if, at any point during the calendar year, the aggregate value of the accounts exceeds $10,000.  An FBAR is required even if the U.S. person does not receive any kind of payment or income from the account during the year.

Are you compliant with your foreign account filings?

Contact Schneider Downs International Tax Services group if you have any questions regarding foreign account filings and visit our webpage to learn about the services that we offer.

Material discussed is meant for informational purposes only, and it is not to be construed as investment, tax, or legal advice. Please note that individual situations can vary. Therefore, this information should be relied upon when coordinated with individual professional advice.

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