Full Analysis of Updated 2012 OVDP Program

- By : P. Patel

the OVDP. The Service also notes that taxpayers may become ineligible for the OVDP once the US government has taken action with regard to the taxpayer’s financial institution. The OVDP

U.S. Taxpayers at New Risk of Audit from OVDP Declines and Withdrawals Campaign

- By : P. Patel

Last year, the US Treasury Inspector General for Tax Administration (TIGTA) released a report which assessed how well that IRS was managing the Offshore Voluntary Disclosure Program (OVDP). OVDP is…

ABA COMMENTS ON THE 2014 OFFSHORE VOLUNTARY DISCLOSURE PROGRAM AND THE STREAMLINED PROGRAMS

- By : P. Patel

the OVDP program again (“2014 OVDP”). One major change was to require full payment up front of the taxes, interest and all penalties. The 2014 OVDP eliminated the reduced penalty…

Top 10 factors to consider before deciding to opt out of OVDI or OVDP

- By : P. Patel

criminal prosecution if they remain in the OVDI and OVDP. If there is a chance of a willfulness finding, you should probably stay in in the OVDI and OVDP. 3….

OVDP Ineligibility Possibility Increases

- By : P. Patel

year, this is a major change: they will likely be ineligible to participate in OVDP. Previously, our law firm counseled HSBC customers to enter the OVDP program as soon as…

Run to the Door: IRS Terminates Offshore Voluntary Disclosure Program (OVDP) effective September 28, 2018

- By : P. Patel

…forward. The number steadily declined through the years, falling to only 600 disclosures in 2017. The current OVDP began in 2014 and is a modified version of the OVDP launched…

Analysis of the new 2012 Offshore Voluntary Disclosure Program (OVDP)

- By : P. Patel

Yesterday the Internal Revenue Service opened its Offshore Voluntary Disclosure Program (OVDP) to encourage more taxpayers with assets in undeclared foreign bank accounts to come forward. While the OVDP was…

File a Protective Claim for Refund for Possible OVDP Opt Out Cases

- By : P. Patel

by agreement. Taxpayers who had submitted under OVDP would have been wise to watch the timing of their submissions against the clock very closely. The OVDP mandated payment for eight…

IRS Form 8938 and the Offshore Voluntary Disclosure Program (OVDP)

- By : P. Patel

aspects of the interaction between Form 8938 and 2012 OVDP. 2012 OVDP and Form 8938 In announcing the 2012 OVDP, IRS cited several reasons for announcing the new voluntary disclosure…

New Post-OVDP IRS Voluntary Disclosure Procedures Announced

- By : P. Patel

The Internal Revenue Service released new updated procedures for voluntary disclosures since the old Offshore Voluntary Disclosure Program (OVDP) closed on September 28, 2018. Last week, IRS deputy commissioner Kirsten…

Article Discusses Termination of Offshore Voluntary Disclosure Program (OVDP) and the Streamlined Filing Compliance Procedures (SFCP)

- By : P. Patel

…we have seen fewer participants in the OVDP program over the last few years, however, the OVDP program remains a good option for certain taxpayers. Separately, we have seen significant…

Denied access to or withdrew from the IRS Offshore Voluntary Disclosure Program (OVDP)?

- By : P. Patel

Voluntary Disclosure Program (OVDP) allows U.S. taxpayers to voluntarily resolve past non-compliance related to unreported offshore income and failure to file foreign information returns. This campaign addresses OVDP applicants who…

Cost of Compliance Rises under OVDP

- By : P. Patel

…a list of banks and institutions that trigger the higher 50-percent penalty under the OVDP. As we have previously noted, the IRS has a series of voluntary disclosure programs and…

OVDP New Forms Announced by IRS

- By : P. Patel

Letter Attachment The new forms (the old forms were simple Word documents) will likely standardize the IRS’ review process for OVDP eligibility, guide the IRS examiner in OVDP “issue spotting”,…

New offshore voluntary disclosure program (OVDP) changes expected to be favorable to taxpayers

- By : P. Patel

…preparing a new offshore voluntary disclosure program (OVDP) that will be easier on “law-abiding” American residents abroad. Koskinen disclosed that, “while the 2012 OVDP and its predecessors have operated successfully,…

What Is The Difference Between the SDOP and the Current OVDP program?: Willfulness

- By : P. Patel

What Is The Difference Between the SDOP and the Current OVDP program? The Streamlined Offshore Procedures (SDOP and SFOP) liberalizes the old restrictions and rewards taxpayers that disclose their offshore…

Offshore Voluntary Disclosure Initiative/Program (OVDI/OVDP) opt-out results and updates

- By : P. Patel

Many of our clients are carefully considering OVDI opt-outs. The opt out option became first available during the 2011 OVDI program, and continues with the current OVDP program. The 2012…

New EZPASS OVDP Without Any Penalties for Non-Resident U.S. Taxpayers

- By : P. Patel

…returns, for the past three years; and delinquent FBARs for the past six years. This seems to be a new EZPASS or express OVDP without any penalties. Taxpayers with higher…

New Taxpayer Advocate Service Report Discusses Optouts out of the OVDI/OVDP

- By : P. Patel

The Taxpayer Advocate Service (TAS) has issued a new mid-year 2013 report. The TAS report discussion regarding optouts out of the OVDI/OVDP is interesting. For the 2009 OVDP (which was…

IRS Announces new OVDP Declines-Withdrawals Campaign

- By : P. Patel

…the IRS Offshore Voluntary Disclosure Program. Entitled, “OVDP Declines-Withdrawals Campaign,” this area of focus involves taxpayers who have applied for the offshore voluntary disclosure program through the pre-clearance process, but…

National Taxpayer Advocate Identifies OVDP Program as a Serious Problem

- By : P. Patel

…the “one-size-fits-all” approach of the IRS Offshore Voluntary Disclosure Program (OVDP), and identified the OVDP program as a most serious problem requiring resolution. The Report states that the IRS discouraged…

IRS Announces New 2012 Offshore Voluntary Disclosure Program (OVDP)

- By : P. Patel

…(OVDP) following continued strong interest from taxpayers and tax practitioners after the closure of the 2011 and 2009 programs. The third offshore program comes as the IRS continues working on…

2018 ABA COMMENTS ON THE OFFSHORE VOLUNTARY DISCLOSURE PROGRAM AND THE STREAMLINED PROGRAMS

- By : P. Patel

duplicative requests for the same data, and, thus, be less burdensome on taxpayers.   II. Additional Comments Provided with Respect to the OVDP Whether a New OVDP Should be Announced…

American Citizens Abroad (ACA) writes letter to IRS Commissioner regarding unfair offshore asset treatment

- By : P. Patel

…disclosure program (OVDP) unfairly, and she ordered several IRS divisions to take various steps to correct this treatment, including allowing taxpayers who had paid penalties under the OVDP to request…

IRS announces new Streamlined Filing Compliance Procedures

- By : P. Patel

Taxpayers who have already entered the 2012 OVDP may be eligible for transitional treatment from the 2012 OVDP. This would effectively apply the $0 or 5 percent penalty to their…

Avoiding and Defining Willfulness

- By : P. Patel

…participants in the OVDP program over the last few years, however, the OVDP program remains a good option for certain taxpayers. Separately, we have seen significant interest and increased participation…

To Opt Out or Not Opt Out: That is the Question

- By : P. Patel

…under 2011 OVDI/OVDP, but may instead assess penalties for a lower amount, if at all. As you can see, although the penalties imposed on participants of the 2011 OVDI/OVDP may…

National Taxpayer Advocate Criticizes IRS over handling of offshore voluntary disclosures

- By : P. Patel

The 2012 National Taxpayer Advocate (NTA) Annual Report to Congress criticized current IRS practices in the Offshore Voluntary Disclosure Program (OVDP) that hinder voluntary compliance by penalizing taxpayers who are…

IRS’s four offshore programs have netted 39,000 taxpayers and over $5.5 billion

- By : P. Patel

…or withdrawals) during the period under review. The median account balance of the more than 10,000 cases closed so far from the 2009 OVDP was $570,000. Participant cases with offshore…

IRS Official Provides Insights for the new IRS Streamlined Compliance Procedures

- By : P. Patel

OVDP, they can do so, but should correspond with the IRS to let the government know they have changed their minds. Best stressed that if taxpayers stay in the OVDP,…

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