Search Results for: sdop
Streamlined Filing Compliance Procedure’s New Revisions to Streamlined Foreign Offshore Procedures (SFOP)
…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…
New IRS guidance Announced for IRS Streamlined 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…
ABA COMMENTS ON THE 2014 OFFSHORE VOLUNTARY DISCLOSURE PROGRAM AND THE STREAMLINED PROGRAMS
…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…
Taxpayers’ Evidence of Non-Willfulness or Willfulness Factors
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…
Another Taxpayer Found Guilty of Failure to File FBARs and Report Foreign Income
…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…
A solution in a tough tax season: the IRS Streamlined 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…
New Warnings in the IRS’ Streamlined Filing Compliance Procedures
…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
…the 2011 and 2009 programs. This 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….
Another Customer with Unreported Offshore Bank Accounts Pleads Guilty
…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 IRS Subpoenae and IRS Data Mining Expected
…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…
News from the 2014 Criminal Fraud and Tax Controversy Conference
…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…
IRS Releases Training Documents on Offshore Voluntary Disclosure Program
…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…