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New Streamlined Domestic Offshore Procedures (SDOP) is a Game Changer

- By : Parag Patel

explore the SDOP and consider filing a carefully drafted SDOP submission.   The IRS detailed announcement of the SDOP follows below: Eligibility for the Streamlined Domestic Offshore Procedures In addition…

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

- By : Parag 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…

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

- By : Parag Patel

…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…

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

- By : Parag Patel

…in the penalty base is inconsistent with the spirit of the SDOP.   For the foregoing reasons, we recommend that the IRS expand SDOP FAQ 1 to provide that assets…

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

- By : Parag Patel

…The SDOP should not result in a penalty base that exceeds the OVDP penalty base. We recommend that the Service expand SDOP Frequently Asked Questions (“FAQ”) 1 to provide that…

Details of the Streamlined Domestic Offshore Procedures

- By : Parag Patel

…(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…

IRS Releases Training Documents on Offshore Voluntary Disclosure Program

- By : Parag Patel

…avoid criminal tax prosecution. The OVDP’s current penalty is 27.5 percent. However there are other alternatives available to certain taxpayers that may provide additional relief, including the SDOP and SFOP…

IRS announces new Streamlined Filing Compliance Procedures

- By : Parag Patel

…reside outside the U.S. ($0 penalty) Streamlined procedures for U.S. residents are referred to as the Streamlined Domestic Offshore Procedures (SDOP). This program is for U.S. citizens or permanent residents…

Details of the Streamlined Foreign Offshore Procedures (SFOP)

- By : Parag Patel

…(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…

Taxpayers’ Evidence of Non-Willfulness or Willfulness Factors

- By : Parag Patel

We have come across the below 3 questions numerous times with our clients. What kind of evidence is relevant to demonstrate “non-willfulness” for purposes of the SDOP and the SFOP…

Major changes to IRS offshore voluntary compliance programs

- By : Parag Patel

…certification program, referred to as the IRS Streamlined filing compliance procedures (SDOP and SFOP); Under this program, taxpayers residing in the United States whose failure to report foreign financial assets…

Streamlined Filing Compliance Procedure’s New Revisions to Streamlined Foreign Offshore Procedures (SFOP)

- By : Parag Patel

…file under the Streamlined Domestic Offshore Procedures (SDOP) or the Streamlined Foreign Offshore Procedures (SFOP). This article focuses on the SFOP. The Internal Revenue Service (IRS) recently modified the non-willfulness…

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

- By : Parag Patel

…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…

New IRS Subpoenae and IRS Data Mining Expected

- By : Parag Patel

…disclosure of offshore assets. The OVDP, SDOP and SFOP compliance programs should be considered with experienced legal counsel. Patel Law Offices has consulted with hundreds of clients regarding their offshore…

Watch Out for Letters From Your Foreign Bank Requesting Information On Your U.S. Residency

- By : Parag Patel

…large penalty or face criminal prosecution. We often recommend that U.S. taxpayers with undisclosed overseas accounts enter into the IRS’s new Streamlined Program (SDOP or SFOP) or Offshore Voluntary Disclosure…

IRS Streamlines its Streamlined Offshore Procedures with More User Friendly Forms

- By : Parag Patel

The IRS has just recently updated the Streamlined Procedure forms for both its “foreign” (SFOP) and “domestic” (SDOP) procedures. All of the information can now be typed directly into the…

New Report: Delinquent Taxpayers Could be Identified at US Border Crossings

- By : Parag Patel

…(non-resident SFOP and domestic SDOP). For those taxpayers who do not meet the eligibility requirements of the Streamline Procedures there is the offshore voluntary disclosure program (OVDP 2014). Share this:…

IRS Clarifies Requirements for Streamlined Filing Procedures

- By : Parag Patel

…instructions for taxpayers residing outside the United States here; New Streamlined Filing Compliance Procedures for U.S. Taxpayers Residing in the United States (SDOP) Frequently Asked Questions and Answers (FAQs) here;…

News from the 2014 Criminal Fraud and Tax Controversy Conference

- By : Parag Patel

…were in attendance. Below are some interesting observations: On the new IRS Streamlined program (including the SDOP and SFOP programs), David Horton LB&I director for international compliance (who is in…

Happy Birthday Streamlined Filing Compliance Procedure!

- By : Parag Patel

…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”)….

Another Customer with Unreported Offshore Bank Accounts Pleads Guilty

- By : Parag Patel

…submission (or maybe SDOP filing) may have saved Mr. Landegger. The case is interesting because it reveals the discussions between the bankers and client, which ultimately were criminally used against…

New Warnings in the IRS’ Streamlined Filing Compliance Procedures

- By : Parag Patel

…Offshore Procedures (SDOP) (for U.S. residents) or Form 14653–Certification by U.S. Persons Residing Outside of the United States for Streamlined Foreign Offshore Procedures (SFOP) (for non-U.S. residents). The streamlined filing…

Hiding Money or Income Offshore Among the “Dirty Dozen” List of Tax Scams for the 2015 Filing Season

- By : Parag Patel

…program will be open for an indefinite period until otherwise announced. The IRS also announced its SDOP and SFOP last year for non-willful cases. Share this: Print More WhatsApp Tweet…

A solution in a tough tax season: the IRS Streamlined Offshore Procedures

- By : Parag Patel

…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…

Another Taxpayer Found Guilty of Failure to File FBARs and Report Foreign Income

- By : Parag Patel

…it’s tax fraud. We are continuing our work to crack down on offshore tax evasion.” A timely filed OVDP submission (or maybe SDOP filing) may have saved Mr. Mukhi. Stay…

New IRS guidance Announced for IRS Streamlined Offshore Procedures.

- By : Parag Patel

…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…

New IRS Disclosure Program Announced for Non-Resident Taxpayers: Streamlined Foreign Offshore Procedures

- By : Parag Patel

…use the Streamlined Domestic Offshore Procedures (SDOP)) taxpayers alike. The SFOP significantly expands the old Streamlined Program for Non US-residents, which was narrowly only for non-filers with less than $1500…