OVDI: Requesting issuance of a FBAR warning letter instead of penalties
In a Tax Notes Today report of statements made at the Eastern Pennsylvania Working Together Conference in Malvern, PA, Jason Kuratnick, IRS Associate Area Counsel (Philadelphia), Small Business / Self-Employed Division is reported to have said: The IRS may send
Opting-out of the Offshore Voluntary Disclosure Initiative: FBAR Penalty Mitigation Guidelines
Depending on the circumstances, we sometimes recommend some taxpayers to opt out of the voluntary disclosure initiative and allow us to demonstrate the absence of willfulness and avoid the normal FBAR penalty regime. We have been aggressively pursuing OVDI opt-outs
The legal standard of “willfulness”: Opt out to avoid high penalties
Under IRS Form 1040, at the bottom of Schedule B, Part III, on Page 2, Question 7(a) states: “at any time during the previous year, did you have any interest in or signatory or other authority over a financial account
Search
Categories
Recent Posts
- Are Trusts Required to Report under the Corporate Transparency Act (CTA)? February 10, 2024
- Is First-Time Abatement Applicable In International Penalty Cases? January 26, 2024
- National Taxpayer Advocate calls IRS Penalties Draconian and Inefficient January 19, 2024
- Crypto is not = Cash currency for IRS reporting January 17, 2024
- Interesting 2023 Foreign Account Cases January 17, 2024
- Fantastic Recommendations for Form 3520 January 15, 2024
- The New IRS ERC Voluntary Disclosure Program January 10, 2024
- AICPA Makes Useful Recommendations For International Forms 3520/3520 January 2, 2024
- New IRS Voluntary Disclosure Program lets employers who received questionable Employee Retention Credits pay them back December 24, 2023
- Parag Patel Esq. Speaks at NJCPA Seminar on”Employee Retention Credit Audit Issues: Surviving IRS Scrutiny” December 20, 2023
- The IRS’s First-Time Abatement (FTA) Penalty Waiver December 19, 2023
- Parag Patel Esq. Speaks at NJCPA Seminar on”The Corporate Transparency Act: What You Need To Know” December 16, 2023