Another foreign bank customer found guilty of foreign income under-reporting and FBAR violations.
A doctor has been convicted of failing to disclose to US federal authorities that he maintained offshore HSBC bank accounts in India and France and hid approximately $8 million in secret foreign bank accounts. Dr. Arvind Ahuja of Wisconsin was
The “Quiet” or “Silent” Disclosure
Our office consults with many clients in determining whether they need to enter into the 2012 IRS Offshore Voluntary Disclosure Program. Because of the high 27.5% penalty in the 2012 OVDP program, many of our clients are considering alternative options
IRS Publishes Useful Chart Outlining Compliance Options for Offshore Assets
The IRS has recently published a useful chart outlining options available to help US taxpayers with offshore interests. The new IRS chart correctly states that it “recognizes that its focus on offshore enforcement efforts and related disclosure programs has raised
To Opt Out or Not Opt Out: That is the Question
When is it appropriate to make a quiet disclosure vs. making a disclosure through the Offshore Voluntary Disclosure Program? This question is not necessarily easy to answer. IRS agents handling OVDI/OVDP cases do not have discretion regarding offshore-related information return
Explore the OVDI opt-out option: Argue for Penalty Mitigation
The revised IRS OVDP FAQs offer helpful guidance on the opt-out option. The newly revised FAQs illustrate the pros and cons of opting out with six examples. See FAQ 51. The examples describe situations in which it may be smart
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