Search Results for: voluntary disclosure programs
IRS Announces New 2012 Offshore Voluntary Disclosure Program (OVDP)
The Internal Revenue Service today reopened the offshore voluntary disclosure program to help people hiding offshore accounts get current with their taxes. The IRS reopened the Offshore Voluntary Disclosure Program…
Run to the Door: IRS Terminates Offshore Voluntary Disclosure Program (OVDP) effective September 28, 2018
…in 2012, which followed voluntary programs offered in 2011 and 2009. The programs have enabled U.S. taxpayers to voluntarily resolve past non-compliance related to unreported foreign financial assets and failure…
IRS Announces New Investigative Units
…been coaxed into voluntary disclosure programs or making so-called “quiet” disclosures out of hiding. Cryptocurrencies The IRS also has been increasingly focused on gathering data regarding cryptocurrencies, sending a John…
IRS Form 8938 and the Offshore Voluntary Disclosure Program (OVDP)
The announcement by the IRS of the opening of the new Offshore Voluntary Disclosure Program (OVDP) on January 9, 2012 came as a surprise to most tax practitioners, especially since…
With No More Amnesty Program: Explore the IRS’s Traditional Voluntary Disclosure program
…forward through the IRS’s traditional Voluntary Disclosure program. Like the OVDI, the traditional Voluntary Disclosure program provides taxpayers an opportunity to come forward and potentially avoid criminal prosecution. The IRS…
The New IRS ERC Voluntary Disclosure Program
…Voluntary Disclosure Program Eligible businesses must apply to the ERC Voluntary Disclosure Program by March 22, 2024. By participating in the program, employers can resolve civil tax liabilities and avoid…
Avoiding and Defining Willfulness
…letters or W-9 forms) or close their accounts. IRS Disclosure Programs Most taxpayers and their representatives now are aware of the various programs allowing taxpayers to correct foreign reporting delinquencies….
IRS Launches Second Offshore Voluntary Disclosure Initiative After Successful Prosecution
…Voluntary Disclosure Initiative (OVDI) is based on the previous disclosure program that ran through October of 2009. The original program helped generate over 15,000 Voluntary Disclosures from U.S. citizens who…
2011 Offshore Voluntary Disclosure Initiative (OVDI)
On February 8, 2011, the IRS announced the 2011 Offshore Voluntary Disclosure Initiative (OVDI), designed to bring offshore money back into the U.S. tax system and help people with undisclosed…
Benefits and consequences of entering or failing to enter the Offshore Voluntary Disclosure Initiative program
…programs. As a result, we have succinctly summarized some of the benefits of entering and consequences of failing to enter the Offshore Voluntary Disclosure Initiative program. Consequences Of Not Entering…
What if You Missed the OVDI Deadline?
Although the OVDI program has expired, a U.S. taxpayer can still make a voluntary disclosure of foreign accounts pursuant to the IRS’s general voluntary disclosure policy. For over 50 years,…
IRS Announces New Rules for FBAR Penalties
…• Criminal Penalties of up to $500,000 or 10 years in jail or both While the penalties can be overwhelmingly high, there have been a host of Voluntary Disclosure Programs…
Received a FATCA Letter from Your Foreign Bank?
…in the various voluntary disclosure programs such as OVDP. A US taxpayer must avail themselves of the voluntary disclosure process prior to an investigation, or they will no longer potentially…
Cost of Compliance Rises under OVDP
…a list of banks and institutions that trigger the higher 50-percent penalty under the OVDP. As we have previously noted, the IRS has a series of voluntary disclosure programs and…
NJ Division of Taxation Offers Offshore Voluntary Compliance Initiative
The New Jersey Department of Treasury, Division of Taxation announced today that it will offer a Second Voluntary Compliance program to complement the Internal Revenue Service Second Special Voluntary Disclosure…
New Comments on the IRS Voluntary Disclosure Program
We are members of the American Bar Association Section of Taxation, which on September 28, 2021 submitted comments to the IRS on the IRS Voluntary Disclosure Program (“VDP”), the Streamlined Domestic Offshore Program…
Bank Leumi: Another Foreign Bank Recommends the IRS Voluntary Disclosure Program
…a December 16 letter Leumi urged U.S. clients to enter the Internal Revenue Service’s voluntary disclosure program, part of a wide-ranging U.S. crackdown on offshore tax dodging.”As published in the…
Major changes to IRS offshore voluntary compliance programs
…offshore voluntary compliance programs, providing new options to help taxpayers residing both overseas and in the United States. The changes are intended to give thousands of people a new avenue…
IRS announces new Streamlined Filing Compliance Procedures
…received at the conclusion of a taxpayer’s disclosure. Anyone affected by the Streamlined Filing Compliance Procedures and the Offshore Voluntary Disclosure Program should have their individual situation carefully reviewed to…
IRS Releases Training Documents on Offshore Voluntary Disclosure Program
last month the IRS released more than 6,500 pages from the Internal Revenue Service on the agency’s Offshore Voluntary Disclosure Program and how it trains its agents. The documents included…
How to Avoid Jail and Clean Up Tax Problems
…as the Voluntary Disclosure Practice (VDP). A taxpayer seeking to make a voluntary disclosure must do so by first requesting preclearance on Form 14457, Voluntary Disclosure Practice Preclearance Request and…
To Opt Out or Not Opt Out: That is the Question
When is it appropriate to make a quiet disclosure vs. making a disclosure through the Offshore Voluntary Disclosure Program? This question is not necessarily easy to answer. IRS agents handling…
Denied access to or withdrew from the IRS Offshore Voluntary Disclosure Program (OVDP)?
This year taxpayers who either were denied access to or withdrew from the IRS Offshore Voluntary Disclosure Program (OVDP) have been receiving Letter 5935 (HERE) from the IRS notifying them…
National Taxpayer Advocate Criticizes IRS over handling of offshore voluntary disclosures
…voluntary disclosure under Criminal Investigation’s Voluntary Disclosure Practice, so long as the taxpayer is fully cooperative in the examination process, by providing all requested foreign records and submitting to interviews,…
The “Quiet” or “Silent” Disclosure
Our office consults with many clients in determining whether they need to enter into the 2012 IRS Offshore Voluntary Disclosure Program. Because of the high 27.5% penalty in the 2012…
Opting Out of the Offshore Voluntary Compliance Initiative Programs
…for a potential audit and imposition of appropriate penalties. The 2012 OVDP program continues the procedures announced in 2011 regarding decisions to “opt out” of the voluntary disclosure penalty structure….
New offshore voluntary disclosure program (OVDP) changes expected to be favorable to taxpayers
…preparing a new offshore voluntary disclosure program (OVDP) that will be easier on “law-abiding” American residents abroad. Koskinen disclosed that, “while the 2012 OVDP and its predecessors have operated successfully,…
Latest Guilty Plea for an Another HSBC Offshore Bank Accountholder
…Offshore Voluntary Disclosure Program. The Offshore Voluntary Disclosure Program was a program administered by the IRS that was intended to serve as a vehicle for U.S. taxpayers to attempt to…
Opting-out of the Offshore Voluntary Disclosure Initiative: FBAR Penalty Mitigation Guidelines
Depending on the circumstances, we sometimes recommend some taxpayers to opt out of the voluntary disclosure initiative and allow us to demonstrate the absence of willfulness and avoid the normal…
Offshore Voluntary Disclosure Initiative/Program (OVDI/OVDP) opt-out results and updates
…OVDP program continues the procedures announced in 2011 regarding decisions to “opt out” of the voluntary disclosure penalty structure. In such a case, IRS agents are instructed to neither punish…