IRS collects over $5 billion in its its offshore voluntary disclosure programs

- By : Parag Patel

The Internal Revenue Service (IRS) has announced that its offshore voluntary disclosure programs (OVDPs) have collected more than $5 billion, and that it has tightened the eligibility requirements of the…

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

- By : Parag Patel

…available to such taxpayers include the Offshore Voluntary Disclosure Program (“OVDP”), the Streamlined Domestic Offshore Program (“SDOP”), and the Streamlined Foreign Offshore Program (“SFOP”).   The IRS voluntary disclosure programs

IRS Offshore Voluntary Disclosure Programs Continue to Burden “Benign Actors” and Damage IRS Credibility

- By : Parag Patel

…series of offshore voluntary disclosure (OVD) programs to settle with taxpayers who had failed to report offshore income and file one or more related information returns (e.g ., Form TD…

National Taxpayer Advocate Delivers Annual Report to Congress that Criticizes Offshore Voluntary Disclosure Programs

- By : Parag Patel

…IRS revisit this decision. The summary of the report is below: OFFSHORE VOLUNTARY DISCLOSURE (OVD): The OVD Programs Initially Undermined the Law and Still Violate Taxpayer Rights Problem Before it…

Offshore Compliance Programs Generate $8 Billion; IRS Urges People to Take Advantage of Voluntary Disclosure Programs

- By : Parag Patel

The IRS issued the below interesting press release last week… IR-2015-116, Oct. 16, 2015 WASHINGTON — With more than 54,000 taxpayers coming in to participate in offshore disclosure programs since…

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

- By : Parag Patel

voluntary disclosure program may pursue available collection   Clarification as to When an OVDP Disclosure is Deemed Timely. The current lack of clarity as to the timeliness of a voluntary

Full Analysis of Updated 2012 OVDP Program

- By : Parag Patel

…our law firm about the 2012 OVDP. Implications Voluntary disclosure of missed information reporting returns (FAQs 17 and 18) Unlike the prior voluntary disclosure Programs, it does not appear the…

New IRS Voluntary Disclosure Program lets employers who received questionable Employee Retention Credits pay them back

- By : Parag Patel

…firm has filed hundreds of IRS voluntary disclosure submissions over the years, and there are numerous similarities to other voluntary disclosure programs. As customary, program eligibility requires no current criminal…

Analysis: IRS New Disclosure Program

- By : Parag Patel

…significant reduction in penalties. Further, it may be harder to estimate the total tax liability for clients prior to submitting their voluntary disclosure application. Other IRS Voluntary Disclosure Programs and…

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

- By : Parag Patel

…series of voluntary disclosure programs in recent years. The OVDP follows on the success of the 2009 Offshore Voluntary Disclosure Program (the 2009 OVDP) and the 2011 Offshore Voluntary Disclosure

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

- By : Parag Patel

…the disclosure of foreign assets. One option is the Offshore Voluntary Disclosure Program (OVDP). Another is the Streamlined Filing Compliance Procedures (SFCP). SFCP is further bifurcated into two sub-programs—one for…

For Tax Professionals: A Guide to the IRS’s Voluntary Disclosure Practice

- By : Parag Patel

…IRS personnel. Voluntary Disclosure does not apply to taxpayers with illegal source income. A Voluntary Disclosure occurs when the taxpayer’s disclosure of the unreported liability is truthful, timely, complete, and…

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

- By : Parag Patel

…IRS’s four offshore programs have resulted in more than 39,000 disclosures by taxpayers, producing over $5.5 billion in revenue. The offshore disclosure programs attract taxpayers by offering a reduced risk…

How to Avoid Criminal Prosecution Through Voluntary Disclosure

- By : Parag Patel

…prosecution. The IRS Criminal Investigations takes such voluntary disclosures under consideration in order to determine whether to recommend criminal prosecution or not. Is Voluntary Disclosure the Way to Go? Voluntary

New IRS Voluntary Disclosure in 7 Steps

- By : Parag Patel

The following are the seven steps of the new updated IRS voluntary disclosure process: A taxpayer will make a voluntary disclosure preclearance request using IRS Form 14457 to IRS Criminal…

IRS announces an update to its Voluntary Disclosure Practice Preclearance Request and Application

- By : Parag Patel

Voluntary Disclosure Practice IRM 9.5.11, Investigative Process – Other Investigations IRM 4.63.3, Withholding and International Individual Compliance – Offshore Voluntary Disclosure Program, Streamlined Filing Compliance Procedures and Voluntary Disclosure Practice…

Upcoming live video webinar: “FBAR and U.S. Tax Reporting: Compliance Requirements for Foreign Assets”

- By : Parag Patel

…on 3/16/2022. Mention code: ZDFCA FBAR and U.S. Tax Reporting: Compliance Requirements for Foreign Assets Unraveling Foreign Asset and Income Reporting Obligations, Navigating Available Voluntary Disclosure Programs This CLE/CPE course…

New Post-OVDP IRS Voluntary Disclosure Procedures Announced

- By : Parag Patel

…Wielobob issued Interim Guidance Memo LB&I-09-1118-014, Updated Voluntary Disclosure Practice (PDF) on November 20, 2018 to supplement procedures regarding the voluntary disclosure practice. The updated procedures apply to all voluntary

New York State Bar Association Proposes OVDI Changes to IRS

- By : Parag Patel

…procedures refer to taxpayers who have not made voluntary disclosures, taxpayers and practitioners have expressed concern that taxpayers who opt out of a voluntary disclosure program will face the same…

IRS Announces Major New changes to the Offshore Voluntary Disclosure Program

- By : Parag Patel

…are announcing today, we provide additional flexibility in key respects while maintaining the central components of our voluntary programs.” Balanced against the modified programs is the government’s ongoing effort to…

2011 Offshore Voluntary Disclosure Initiative Frequently Asked Questions (FAQs) and Answers

- By : Parag Patel

We have reviewed the new 2011 OVDI FAQs and noticed that the Service has refined and streamlined the voluntary disclosure process. Our firm prepared dozens of voluntary disclosure applications in…

IRS Collects $10 Billion From Voluntary Disclosures of Foreign Assets

- By : Parag Patel

…changed. The IRS’s series of Offshore Voluntary Disclosure Programs are not the only factor prompting taxpayers to disclose their foreign bank accounts. In 2010, Congress passed the Foreign Account Tax…

The New IRS Voluntary Disclosure Practice: Not a Good Deal for Noncompliant Taxpayers

- By : Parag Patel

For all voluntary disclosures received after September 28, 2018, the IRS has a new program called the Voluntary Disclosure Practice (VDP), which is for both domestic and international noncompliance. Unlike…

Foreign bank account reports (FBARs) and the 2011 Offshore Voluntary Disclosure Initiative (2011 OVDI)

- By : Parag Patel

voluntary disclosure program for U.S. persons with unreported foreign financial accounts and other foreign assets. The 2011 Offshore Voluntary Disclosure Initiative (2011 OVDI) is based on a similar voluntary disclosure

Time Running Out for HSBC India accountholders sought by IRS

- By : Parag Patel

…otherwise available outside the OVDI. Is Voluntary Disclosure Right for You? The factors involved in determining whether a taxpayer should make a voluntary disclosure are numerous and complex. A taxpayer…

Swiss Government and US Government Announce New Program for Cooperation and Disclosure by Swiss Banks

- By : Parag Patel

voluntary disclosure program for banks, with features comparable to those of the voluntary disclosure programs offered by the US Internal Revenue Service in recent years to US persons with undisclosed…

IRS Updated Voluntary Disclosure Practice is a Game-Changer

- By : Parag Patel

Last week the IRS released a memorandum with new procedures for an “Updated Voluntary Disclosure Practice” impacting all voluntary disclosures. The new updated voluntary disclosure practice (VDP) is a game-changer…

New voluntary disclosure program for offshore accounts in 2011

- By : Parag Patel

…in the first voluntary disclosure initiative for offshore accounts in 2009. Last December, the Commissioner of the Internal Revenue Service announced that the IRS may institute a second Voluntary Disclosure

What HSBC India Accountholders Can Expect From the IRS

- By : Parag Patel

…a taxpayer should make a voluntary disclosure are numerous and complex. A taxpayer considering making a voluntary disclosure may want to discuss the matter with experienced legal counsel. Such a…

Government Report Advises IRS to Increase Awareness of Offshore Account Rules to Help Immigrants

- By : Parag Patel

…not targeted outreach efforts to new immigrants, the GAO’s report said. “Obtaining information on how taxpayers found out about IRS’s offshore voluntary disclosure programs could help IRS better identify populations…