On November 29, 2018, the IRS released a memorandum that addressed the process for all voluntary disclosures following the end of the Offshore Voluntary Disclosure Program (“OVDP”) on September 28, 2018. The new voluntary disclosure
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 Investigation (CI). Taxpayers can request
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 for offshore voluntary disclosures for US persons
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 Wielobob issued Interim Guidance Memo LB&I-09-1118-014,
Today the New Jersey Division of Taxation announced the launch of their Tax Amnesty program. The program is intended to provide individuals and businesses with the opportunity to pay back taxes or file past returns
If you do not pay your taxes, the IRS may revoke your passport. As the National Taxpayer Advocate (NTA) Nina E. Olson has recently pointed out in her blog, when a taxpayer is notified of such pending
Enacted legislation requires the New Jersey Division of Taxation to establish a 90-day state tax amnesty period that ends no later than January 15, 2019. The Legislature had previously passed a bill requiring a six-month
Our article on the new tax law was published today by the American Bar Association below… https://www.americanbar.org/groups/gpsolo/publications/gpsolo_ereport/2018/june-2018/tcja-future-american-taxpayers.html The TCJA and the Future of American Taxpayers Vol. 7, No. 11 Parag Patel and Anannya Tripathy Parag Patel,
Recently, the U.S. District Court for the Western District of Texas in U.S. v. Colliot, determined that an individual who repeatedly failed to timely file Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts, commonly
We are members of the American Bar Association Section of Taxation, which on May 2, 2018 submitted comments to the IRS on the IRS Offshore Voluntary Disclosure Program (“OVDP”), the Streamlined Domestic Offshore Program (“SDOP”), and the
There is a debate as to the “burden of proof” that must be met by the Internal Revenue Service (IRS) in asserting that an FBAR violation was “willful”. This is significant because those who willfully
The IRS again reminded taxpayers yesterday about their reporting obligations for foreign assets and income. The reminder again represents the IRS’ targeted enforcement of tax laws for reporting obligations for foreign assets and income. Taxpayers should take
