Search Results for: diirsp
The New DIIRSP: I like the old better
…The new DIIRSP fails on both counts. I like the old DIIRSP better. Taxpayers should now cautiously enter the DIIRSP only under the right (and favorable) circumstances. For taxpayers who…
IRS Revises Delinquent International Information Return Submission Procedure (DIIRSP)
The IRS revised its Delinquent International Information Return Submission Procedure (DIIRSP) last week. The DIIRSP provided an alternative 0% penalty voluntary disclosure process to taxpayers other than the Offshore Voluntary…
Details of the Delinquent International Information Return Submission Procedures (DIIRSP)
…a fact specific submission, which is based on each applicant’s facts and circumstances. A taxpayer may utilize DIIRSP if the taxpayer has not filed one or more required international information…
All the Many FBAR Late Filing Procedures
…penalized if they filed the necessary delinquent forms. Our firm has still had great success with the old and new DIIRSP program. To learn more about DIIRSP go to: https://patellawoffices.com/blog/planning-for-tax-minimization/irs-revises-delinquent-international-information-return-submission-procedure-diirsp/…
Foreign Proprietorship: Form 8858 Filing Requirement
…are disqualified from using this procedure. We have used the DIIRSP for hundreds of clients to solve their tax problems. Contact our office to learn more about the DIIRSP procedure….
Penalty relief for International Information Forms 5471, 5472, and 8865
…Delinquent International Information Return Submission Procedures (DIIRSP): The IRS’s Delinquent International Information Return Submission Procedures offer taxpayers a path for mitigating exposure to international information return penalties, in cases where…
Foreign Gift Received: Form 3520 Penalties Eliminated in New Court Case
…Delinquent Informational Return Submission Procedures (DIIRSP). The IRS nevertheless assessed penalties (25%) totaling $207,500 under IRC 6039F(c)(1). The case is similar to many of our clients’ situations where large penalties…
Welcome news from IRS for late Form 3520 penalties
…a DIIRSP statement attached, was resulting in the automatic assessment of penalties, most often a flat $10,000 per form, or more if the assets reported rose above certain thresholds. Following the…
New Comments on the IRS Voluntary Disclosure Program
…as the Delinquent International Information Return Submission Procedures (“DIIRSP”). The Amended Notice observes that the VDP and the SFCP offer “two very different compliance paths to two very different populations…