National Taxpayer Advocate Criticizes IRS over handling of offshore voluntary disclosures

- By : Parag Patel

The 2012 National Taxpayer Advocate (NTA) Annual Report to Congress criticized current IRS practices in the Offshore Voluntary Disclosure Program (OVDP) that hinder voluntary compliance by penalizing taxpayers who are…

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

- By : Parag Patel

…or withdrawals) during the period under review. The median account balance of the more than 10,000 cases closed so far from the 2009 OVDP was $570,000. Participant cases with offshore…

IRS Official Provides Insights for the new IRS Streamlined Compliance Procedures

- By : Parag Patel

OVDP, they can do so, but should correspond with the IRS to let the government know they have changed their minds. Best stressed that if taxpayers stay in the OVDP,…

IRS Announces Major New changes to the Offshore Voluntary Disclosure Program

- By : Parag Patel

OVDP. The expanded streamlined procedures are intended for U.S. taxpayers whose failure to disclose their offshore assets was non-willful. More than 45,000 taxpayers have participated in the IRS programs so…

Most Swiss banks participating in the US Department of Justice (DOJ) amnesty program seek extension to disclose

- By : Parag Patel

…US taxpayers that have unreported foreign assets to participate in the IRS Off-shore Voluntary Disclosure Program (OVDP) or seek to correct tax noncompliance through other avenues. The OVDP offers an…

Method to Cure Delinquent or Incomplete Foreign Information Returns Without Penalties

- By : Parag Patel

Last year, the IRS announced its third offshore voluntary disclosure initiative. Like the earlier initiatives, the 2012 OVDP is designed to encourage taxpayers with unreported offshore accounts and assets to…

The “Quiet” or “Silent” Disclosure

- By : Parag Patel

OVDP, but may instead assess penalties for a lower amount, if at all. Although the penalties imposed on participants of the 2012 OVDP are definitively high, the same cannot be…

Analysis: IRS New Disclosure Program

- By : Parag Patel

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,…

Instructions for New Streamlined Filing Compliance Procedures for Non-Resident, Non-Filer U.S. Taxpayers

- By : Parag Patel

…described in this document, OVDP is no longer available. It should also be noted that taxpayers who are ineligible to use OVDP are also ineligible to participate in this procedure….

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

- By : Parag Patel

…obligations. Both the Offshore Voluntary Disclosure Program (OVDP) and the streamlined procedures enable taxpayers to correct prior omissions and meet their federal tax obligations while mitigating the potential penalties of…

Swiss Banks’ Deadline to Disclose Information is Extended

- By : Parag Patel

…in the IRS Off-shore Voluntary Disclosure Program (OVDP) or seek to correct tax noncompliance through other avenues. The OVDPoffers an incentive for delinquent tax payers to disclose their offshore accounts….

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

- By : Parag Patel

…eligible for the OVDP. The IRS also put taxpayers on notice that their eligibility for OVDP could be terminated once the US government has taken action in connection with their…

IRS Announces New Statistics Regarding Voluntary Disclosures

- By : Parag Patel

Since the initiation of the U.S. Internal Revenue Service’s (IRS) Offshore Voluntary Disclosure Program (OVDP) which originally began in 2009 and the Streamlined Filing Compliance Procedures first offered on September…

Major changes to IRS offshore voluntary compliance programs

- By : Parag Patel

…obligations: The Offshore Voluntary Disclosure Program (OVDP); Taxpayers whose conduct was likely willful are directed to the OVDP—where they pay a much higher 27.5% miscellaneous offshore penalty; A new non-willful…

The Tax Heat is On

- By : Parag Patel

…to report and remit associated taxable income to the United States. Taxpayers who desire to disclose to the Service a foreign account have a choice between the OVDP, the latest…

New Leak of Offshore Accountholders Highlights the Need to Clean Up

- By : Parag Patel

…the OVDP, and the newer streamlined procedures. The OVDP remains the safest and most foolproof program, with amnesty even for willful acts. But for those with the right facts, the…

Delinquent or unfiled IRS Form 5471

- By : Parag Patel

…amended U.S. federal tax return including a persuasive compelling reasonable cause statement. Contact our office to discuss this good option. Offshore Voluntary Disclosure Program (OVDP)The IRS OVDP is designed for…

IRS reminds those with foreign assets about U.S. tax obligations

- By : Parag Patel

…28, 2018. Taxpayers with undisclosed foreign financial assets still have time to use OVDP before the deadline. For further details about the OVDP, see the OVDP FAQs. The IRS noted…

New FBAR Court Case Makes it Easier for Taxpayers to be Deemed Willful

- By : Parag Patel

…of a known legal duty. Garrity merely continues a trend of cases that have effectively expanded the definition of “willful” conduct when it comes to FBAR penalties. OVDP Closing The…

Educational Panel Discussion: The U.S. Government’s Global Crackdown on Tax Evasion: Where It Has Been and Where It Is Going

- By : Parag Patel

…regarding some details of the US DOJ Program for Swiss Banks. She said that the information received from US DOJ Program for Swiss Banks and OVDP will lead to new…

IRS Publishes Useful Chart Outlining Compliance Options for Offshore Assets

- By : Parag Patel

…FBARs for the past six years. This could be considered a “quiet” disclosure. In OVDP FAQ #15 the IRS states “Those taxpayers making “quiet” disclosures should be aware of the…

Reasons to Opt Out of the 2011 OVDI Program

- By : Parag Patel

…FBAR penalty assessed against those opting out of the 2009 OVDP is only $15,737.19 on average. This average is according to the IRS’ response to TAS information request (Oct. 23,…

Opt Out of OVDI Program Penalties to Get a Lower Penalty

- By : Parag Patel

Under the 2011 Offshore Voluntary Disclosure Initiative (OVDI) or 2012 Offshore Voluntary Disclosure Program (OVDP), the 2012 program gives no discretion to the IRS agents to reduce penalties. If a…

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

- By : Parag Patel

…years of amended income tax returns and assesses no penalty on any account balance. In comparison, the current OVDP program requires eight years of returns and a 27.5% penalty. In…

New Comments of the IRS’ New Streamlined Filing Compliance Procedures for Non-Resident Non-Filer U.S. Taxpayers

- By : Parag Patel

…believes that the New Streamlined Filing Compliance Procedures for Non-Resident, Non-Filer U.S. Taxpayers is an excellent alternative to OVDP for Non-Resident U.S. Taxpayers. The IRS’ New Filing Compliance Procedures for…

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

- By : Parag Patel

…increases “education and outreach.” Based on a review of cases for the 2009 Offshore Voluntary Disclosure Program (OVDP), the GAO found examples of immigrants who stated that they were unaware…

US DOJ Tax Asst Attorney General Keneally Reports that One third of Swiss Banks Joining US DOJ Swiss Bank Program

- By : Parag Patel

…Swiss bank account should strongly consider disclosing that account now through the IRS Offshore Voluntary Disclosure Program (OVDP). The OVDP is a voluntary compliance initiative whereby individuals can receive amnesty…

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

- By : Parag Patel

…The SDOP requires filing only three years of amended income tax returns and assesses a 5% penalty of the highest account balance. In comparison, the current OVDP program requires eight…

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

- By : Parag Patel

…disclosed foreign assets to the U.S. government. The IRS introduced SFCP in June 2014 as an alternative to its existing Offshore Voluntary Disclosure Program (OVDP), which was designed more for…

IRS Announces New Clarifying FAQs for Streamlined Offshore Compliance Program

- By : Parag Patel

…Streamlined Filing Compliance Procedures is specifically applying OVDP regime principles. If appropriate, this could lead to the possibility of analogizing of principles and nuances from the OVDP regime (with 55+…