Recent Court Decision Shows Risks of IRS Streamlined Filing Compliance Procedures

…estate (Taxpayer) attempted to become compliant through the IRS’s Streamlined Domestic Offshore Procedures (“SDOP”). The IRS flagged the submission and assessed the maximum willful FBAR penalties against the Taxpayer because…

All the Many FBAR Late Filing Procedures

…Streamlined Domestic Offshore Procedures or SDOP The SDOP are for Taxpayers who are not qualified as foreign residents, non-willful, and filed their original tax returns on time. Under the SDOP

New Comments on the IRS Voluntary Disclosure Program

…(“SDOP”), and the Streamlined Foreign Offshore Program (“SFOP”). In the past we co-authored the ABA comments, this year we did not but the comments are very constructive. It is hoped…

Solution: Streamlined Domestic Offshore Procedures

…file under the Streamlined Domestic Offshore Procedures (SDOP) or the Streamlined Foreign Offshore Procedures (SFOP). Our firm has recently received many inquiries regarding these new IRS Streamlined Offshore Procedures. These…

Happy Birthday Streamlined Filing Compliance Procedure

…the disclosure of foreign assets. SFCP has two sub-programs: one for US residents (Streamlined Domestic Offshore Procedures or “SDOP”) and one for non-US residents (Streamlined Foreign Offshore Procedures or “SFOP”)….

Consequences of Filing False Streamlined Filings

…taxpayer to file an SDOP when there was willful conduct resulting in harsh consequences. Taxpayers who fraudulently file an SDOP face criminal prosecution. Recently, the IRS has taken fraudulent filings…

Details of the Streamlined Foreign Offshore Procedures (SFOP)

(SDOP) or the Streamlined Foreign Offshore Procedures (SFOP). This article focuses on the SFOP. The Internal Revenue Service (IRS) recently modified the non-willfulness certification form that individual taxpayers must submit…

Details of the Streamlined Domestic Offshore Procedures

(SDOP) or the Streamlined Foreign Offshore Procedures (SFOP). This article focuses on the SDOP, which is for taxpayers who reside in the United States. The Internal Revenue Service (IRS) recently…

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

…Streamlined Domestic Offshore Program (“SDOP”), and the Streamlined Foreign Offshore Program (“SFOP”). We co-authored the ABA comments. The comments are very constructive. It is hoped that the IRS carefully considers…

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

…US residents (Streamlined Domestic Offshore Procedures or “SDOP”) and one for non-US residents (Streamlined Foreign Offshore Procedures or “SFOP”). Each program has its own set of tailored procedures and eligibility…

Happy Birthday Streamlined Filing Compliance Procedure!

…the disclosure of foreign assets. SFCP has two sub-programs: one for US residents (Streamlined Domestic Offshore Procedures or “SDOP”) and one for non-US residents (Streamlined Foreign Offshore Procedures or “SFOP”)….

Streamlined Filing Compliance Procedure’s New Revisions to Streamlined Domestic Offshore Procedures (SDOP)

…file under the Streamlined Domestic Offshore Procedures (SDOP) or the Streamlined Foreign Offshore Procedures (SFOP). This article focuses on the SDOP, which is for taxpayers who reside in the United…