Happy Birthday Streamlined Filing Compliance Procedure!

- By : Parag Patel

…the disclosure of foreign assets. SFCP has two sub-programs: one for US residents (Streamlined Domestic Offshore Procedures or “SDOP”) and one for non-US residents (Streamlined Foreign Offshore Procedures or “SFOP”)….

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

- By : Parag Patel

…US residents (Streamlined Domestic Offshore Procedures or “SDOP”) and one for non-US residents (Streamlined Foreign Offshore Procedures or “SFOP”). Each program has its own set of tailored procedures and eligibility…

Avoiding and Defining Willfulness

- By : Parag Patel

…interest. On July 1, 2014, the IRS created the Streamlined Disclosure Programs for taxpayers with non-willful failures to report foreign assets and accounts. Under these programs, taxpayers are only required…

IRS Announces New Statistics Regarding Voluntary Disclosures

- By : Parag Patel

…popular streamlined filing compliance procedures. Both the OVDP and the streamlined procedures enable taxpayers to correct prior omissions and regularize their affairs while mitigating penalties. For those who are not…

New Comments on the IRS Voluntary Disclosure Program

- By : Parag Patel

…by U.S. Person Residing Outside of the United States for Streamlined Foreign Offshore Procedures, and Form 14654, Certification by U.S. Person Residing in the United States for Streamlined Domestic Offshore…

IRS Announces Major New changes to the Offshore Voluntary Disclosure Program

- By : Parag Patel

streamlined procedures to accommodate a wider group of U.S. taxpayers who have unreported foreign financial accounts. The original streamlined procedures announced in 2012 were available only to non-resident, non-filers. Taxpayer…

Correcting Common FBAR Errors

- By : Parag Patel

…being filed pursuant to the “IRS’s Delinquent FBAR Submission Procedures.” 3. File Pursuant to the IRS’s Streamlined Filing Compliance Procedures The IRS’s Streamlined Filing Compliance Procedures (commonly referred to as…

Penalty relief for International Information Forms 5471, 5472, and 8865

- By : Parag Patel

…include an original international information return. Streamlined Filing Compliance Procedures (SFCP): The IRS’s Streamlined Filing Compliance Procedures are available to taxpayers who can certify that their failure to report foreign financial…

News from the 2014 Criminal Fraud and Tax Controversy Conference

- By : Parag Patel

…charge of the IRS Streamlined program), said that there are differences between the OVDP and Streamlined, particularly noting to Streamlined “requires a certification of non-willfulness, and a false certification could…

IRS Collects $10 Billion From Voluntary Disclosures of Foreign Assets

- By : Parag Patel

…made use of separate streamlined procedures to correct their previous omissions and meet their federal tax obligations, paying approximately $450 million in taxes, interest and penalties. The Offshore Voluntary Disclosure…

ABA Conference with Government Officials

- By : Parag Patel

…issues of interest. Also discussed was the effect of streamlined program to channel most taxpayers into streamlined rather than OVDP. Government official John McDougal said that the average $10,000 payment…

What Is The Difference Between the SDOP and the Current OVDP program?: Willfulness

- By : Parag Patel

What Is The Difference Between the SDOP and the Current OVDP program? The Streamlined Offshore Procedures (SDOP and SFOP) liberalizes the old restrictions and rewards taxpayers that disclose their offshore…

Run to the Door: IRS Terminates Offshore Voluntary Disclosure Program (OVDP) effective September 28, 2018

- By : Parag Patel

…Fort, Chief, IRS Criminal Investigation. “Stopping offshore tax noncompliance remains a top priority of the IRS.” Streamlined Procedures and Other Options A separate program, the Streamlined Filing Compliance Procedures, for…

The Tax Heat is On

- By : Parag Patel

…IRS Streamlined program for non-willful violations is far simpler and much less costly. The Streamlined programs came with the 2014 improvements to the OVDP, which sparked and renewed interest in…

New Leak of Offshore Accountholders Highlights the Need to Clean Up

- By : Parag Patel

…IRS Streamlined program for non-willful violations is far simpler and much less costly. The Streamlined programs came with the 2014 improvements to the OVDP, which sparked and renewed interest in…

All the Many FBAR Late Filing Procedures

- By : Parag Patel

…SDOP program submissions. To learn more of SDOP go to: https://patellawoffices.com/blog/planning-for-tax-minimization/new-streamlined-domestic-offshore-procedures-sdop-is-a-game-changer-2/  Streamlined Foreign Offshore Procedures or SFOP To be eligible for this program, a Taxpayer must be qualified as a…

New IRS internal procedure guidance for Streamline Filing Compliance Procedures

- By : Parag Patel

…receiving follow up inquires from the IRS for some of our streamlined program filers.   The streamlined program offers a good option for many taxpayers with undeclared accounts. Our firm…

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…

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

- By : Parag Patel

streamlined program in 2014 in ways that allow many taxpayers to pay lower penalties. However, the new rules do not allow taxpayers who already had entered into closing agreements with…

IRS Updated Voluntary Disclosure Practice is a Game-Changer

- By : Parag Patel

…change other IRS programs, such as the IRS Streamlined Compliance Procedures (for non-willful US persons) including the popular Streamlined Domestic Offshore Procedures and Streamlined Foreign Offshore Procedures. The Updated VDP…

Delinquent or unfiled IRS Form 5471

- By : Parag Patel

…should do if you have unfiled or incorrect Forms 5471? Here are a few resources to help you begin to understand this issue:     IRS’ new Streamlined Filing Compliance…

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

- By : Parag Patel

…those with simple returns and owing less than $1,500 in tax – to file the returns without triggering penalties (the “Streamlined Nonresident Filing Initiative”). In January 2013, following the National…

Top myths of US tax compliance for Foreign Accountholders

- By : Parag Patel

…has major penalties. However, the IRS has modified one of its amnesty programs, the Streamlined Offshore Filing Procedures, to eliminate late filing and FBAR (Foreign Bank Account Report) penalties. Under…

Delinquent FinCen Form 114 (FBAR) Filings

- By : admin

…certification forms required to be filed by taxpayers seeking to avail themselves of the Streamlined Filing Compliance Procedures. The streamlined program was significantly expanded by the IRS in June 2014…

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

- By : Parag Patel

…it will continue to use tools besides voluntary disclosure to combat offshore tax avoidance, including taxpayer education, whistleblower leads, civil examination and criminal prosecution. The IRS continues to use streamlined

Major changes to IRS offshore voluntary compliance programs

- By : Parag Patel

…certification program, referred to as the IRS Streamlined filing compliance procedures (SDOP and SFOP); Under this program, taxpayers residing in the United States whose failure to report foreign financial assets…

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

…prosecutions. Davis said that the government is comparing records from the Swiss bank program with OVDP filings and streamlined program certifications of non-willfulness and will likely prosecute some willful taxpayers….

IRS Revises Delinquent International Information Return Submission Procedure (DIIRSP)

- By : Parag Patel

…Disclosure Program or the Streamlined Filing Compliance Procedures to file delinquent international information returns. We have successfully filed hundreds of DIIRSP filings for clients since the DIIRSP program was started…

New Post-OVDP IRS Voluntary Disclosure Procedures Announced

- By : Parag Patel

…due to a willful failure to report foreign financial assets and pay all tax due in respect of those assets.” The memo does NOT terminate or modify the IRS’ Streamlined

New Form 3520 Penalties

- By : Parag Patel

…a new program to receive delinquent Form 3520 filings and to review the reasonable cause. This program would be similar to the streamlined filing compliance procedures for reporting and paying…