...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...
...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...
...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...
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...
...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...
...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...
...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...
...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....
...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...
...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...
...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...
...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...
