New IRS internal procedure guidance for Streamline Filing Compliance Procedures

- By : Parag Patel

…option for many taxpayers with undeclared accounts. Our firm presented an informational webinar on the Streamlined Filing Compliance Procedures. Materials from the webinar can be downloaded here: Game Changer Streamline….

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…

IRS Streamlines its Streamlined Offshore Procedures with More User Friendly Forms

- By : Parag Patel

…Offshore Procedures. The streamlined filing compliance procedures are designed for only individual taxpayers, including estates of individual taxpayers. The streamlined procedures are available to both U.S. individual taxpayers residing outside…

Avoiding and Defining Willfulness

- By : Parag Patel

…disclosure program to pursue. Our firm presented an informational webinar on the Streamlined Filing Compliance Procedures. Materials from the webinar can be downloaded here: Game Changer Streamline. Patel Law Offices…

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…

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

…protection from potential criminal prosecution can continue to correct past mistakes using the IRS’ Streamlined Filing Compliance Procedures or other procedures. The updated procedures contain a new “Civil Resolution Framework”…

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

- By : Parag Patel

filing compliance procedures that will remain in place and be available to eligible taxpayers. But, as with OVDP, the IRS said it may end the streamlined filing compliance procedures at…

New Comments on the IRS Voluntary Disclosure Program

- By : Parag Patel

…Service’s Streamlined Filing Compliance Procedures (“SFCP”). The SFCP, which were first offered on September 1, 2012, provide taxpayers who failed to report foreign income, assets, accounts, or investments, or pay…

IRS Collects $10 Billion From Voluntary Disclosures of Foreign Assets

- By : Parag Patel

…issues to come forward to meet their tax obligations.” The IRS has developed a Streamlined Filing Compliance Procedures that is open to taxpayers who have not been willfully avoiding taxes….

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…

IRS Provides Form 5471 Information-Filing Relief For Dormant Foreign Corps.

- By : Parag Patel

…with a qualified professional well versed in international taxation. IRS: Rev. Proc. 92-70; 1992-2 C.B. 435 SECTION 1. PURPOSE This revenue procedure provides a summary filing procedure for filing Form…

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”)….

Delinquent or unfiled IRS Form 5471

- By : Parag Patel

Procedures: The Internal Revenue Service has recently updated the certification forms required to be filed by taxpayers seeking to avail themselves of the Streamlined Filing Compliance Procedures with with 0%…

Solution: Streamlined Domestic Offshore Procedures

- By : Parag Patel

…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…

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…

IRS posts its “wins” involving offshore accounts

- By : Parag Patel

http://www.irs.gov/uac/Offshore-Tax-Avoidance-and-IRS-Compliance-Efforts Offshore Tax-Avoidance and IRS Compliance Efforts The IRS continues to uncover abusive tax-avoidance schemes involving offshore activity. Find information here pertaining to Union Bank of Switzerland (UBS). Aug. 19,…

Analysis: IRS New Disclosure Program

- By : Parag Patel

…Correction Procedures Remain Unaffected The memorandum importantly states that the IRS’ Streamlined Filing Compliance Procedures, the Delinquent FBAR submission procedures, and the Delinquent International Information Return submission procedures are still…

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…

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”)….

IRS delinquent FBAR submission procedure

- By : Parag Patel

…counsel in filing the delinquent FBAR submission procedure. Delinquent FBAR Submission Procedures Taxpayers who do not need to use either the OVDP or the Streamlined Filing Compliance Procedures to file…

New FinCEN Form 114 (FBAR) Filing Rules Announced

- By : Parag Patel

…was needed to explain a delinquent FBAR filing, filers were required to attach supporting addenda. FinCEN recently addressed these limitations with new documentation and filing procedures. New changes to e-filing

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…

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

- By : Parag Patel

…including the offshore program and streamlined procedures, to come back into full compliance with their tax obligations.” Under the Foreign Account Tax Compliance Act (FATCA) and the network of intergovernmental…

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

…on the U.S. Laws for Foreign Accounts Compliance SABANA seminar. Also discussed were the Streamlined Filing Compliance Procedures, which are available to taxpayers certifying that their failure to report foreign…

The New DIIRSP: I like the old better

- By : Parag Patel

…the taxpayer has not failed to report tax.  Old DIIRSP: Before the change, the DIIRSP originally stated: Taxpayers who do not need to use the OVDP or the Streamlined Filing

2 recent IRS developments that will impact Indian Americans

- By : Parag Patel

…an option. “The filing of an amended income tax return has heighted audit risk (probably significantly greater than the original filed return). The filing of a delinquent FBAR also has…

IRS Releases New IRS 2022 FBAR Fact Sheet

- By : Parag Patel

…114a, Record of Authorization to Electronically File FBARs PDF, and: All reportable financial accounts of the non-filing spouse are jointly owned with the filing spouse, and The filing spouse reports all…

Protective Filing of Information Returns

- By : Parag Patel

Filing Obligations U.S. citizens, U.S. green card holders and U.S. corporations are clearly required to file a U.S. income tax return each year if their income meets the filing threshold….

More Tax Complexity: New Form 8938

- By : Parag Patel

…Year: $200,000 Filing Status: Married Filing Separate Aggregate Value at Year End: $50,000 Highest Aggregate Value at Any Time During the Year: $100,000 Filing Status: Taxpayer Living Abroad (Non-Joint) Aggregate…