Streamlined Filing Compliance Procedure’s New Revisions to Streamlined Domestic Offshore Procedures (SDOP)

- By : P. Patel

…in June 2014 as an alternative to its existing Offshore Voluntary Disclosure Program (OVDP), which was designed more for taxpayers with evidence of willful failure to disclose foreign assets. Specifically,…

IRS Announces New Investigative Units

- By : P. Patel

…scouring its data collected from Foreign Account Tax Compliance Act (“FATCA”) reporting, the Offshore Voluntary Disclosure Program (“OVDP”), and the Swiss Bank Program, and analyzing data published by whistleblowers, including…

New IRS Voluntary Disclosure in 7 Steps

- By : P. Patel

OVDP program). CI will not process tax returns or tax payments. CI will notify the taxpayer by letter of preliminary acceptance of the voluntary disclosure submission. CI will forward the…

Opt-Out Guidance for the 2011 OVDI

- By : P. Patel

…Removal Guide for the 2009 OVDP and 2011 OVDI. The guide is posted to the website. Taxpayers are reminded, that even after opting out of the Service’s civil settlement structure,…

New FinCEN Form 114 (FBAR) Filing Rules Announced

- By : P. Patel

…procedures Delinquent FBARs The IRS on July 24, 2013 updated its Frequently Asked Questions (FAQs) for its Offshore Voluntary Disclosure Program (OVDP). Under the OVDP’s 2012 announcement, the IRS provided…

New IRS Subpoenae and IRS Data Mining Expected

- By : P. Patel

…detailed information to E-Trak by participating in IRS’s Offshore Voluntary Disclosure Program (OVDP). The IRS’s use of E-Trak in the last few years has greatly improved its ability to find…

News from the 2014 Criminal Fraud and Tax Controversy Conference

- By : P. 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…

New IRS internal procedure guidance for Streamline Filing Compliance Procedures

- By : P. Patel

…(Forms 3520, 3520-A, 5471, 5472, 8938, 926, or 8621) by e-mailing the CIS ID number to “*LB&I OVDP Compliance” with an explanation that the case is being forwarded due to…

U.S. Signs FATCA Pacts with Malta, Netherlands, Bermuda, Jersey, Guernsey and Isle of Man

- By : P. Patel

…several clients with accounts in these jurisdictions. We counseled them into the OVDP program and they fortunately and successfully are all in the OVDP program, otherwise the new FATCA agreements…

Global Enforcement of FATCA: Something to Worry About

- By : P. Patel

…a competent tax lawyer and consider participating in the 2012 OVDP program. Although the 2012 OVDP penalty regime may seem overly harsh for many, the decision to participate should include…

Foreign Account Tax Compliance Act (FATCA) online registration program is launched

- By : P. Patel

…consider participating in the IRS OVDP program. Although the OVDP penalty regime may seem overly harsh for many, the decision to participate should include an economic analysis of the taxpayer’s…

HSBC Payment of Largest Penalty and FATCA Encourages Taxpayers to Disclose

- By : P. Patel

…Disclosure Program (OVDP) is no longer an option. Only through the OVDP is a person virtually shielded from criminal prosecution and the threat of incarceration. According to Senator Carl Levin,…

IRS Notices for OVDI Program

- By : P. Patel

…the 2009 OVDP, the IRS now appears to be applying all of the separate annual payments to the 2007 tax year alone. This means that interest continues to accrue for…

Helpful Non-willful FBAR penalty case decided by court

- By : P. Patel

…$300,000 and $550,000. Mr. Moore filed no FBARs until at least 2009. Around that time, he became aware of IRS’s voluntary offshore disclosure program (OVDP) to encourage people who had…

The Teeth of the Foreign Account Tax Compliance Act (FATCA)

- By : P. Patel

…undisclosed foreign accounts should consult a competent tax lawyer and consider participating in the 2012 OVDP program. Although the 2012 OVDP penalty regime may seem overly harsh for many, the…

Hiding Money or Income Offshore Among the “Dirty Dozen” List of Tax Scams for the 2015 Filing Season

- By : P. Patel

…requirements in order.” Since the first Offshore Voluntary Disclosure Program (OVDP) opened in 2009, there have been more than 50,000 disclosures and we have collected more than $7 billion from…

Significant FBAR Penalties Upheld by Court

- By : P. Patel

…the IRS on her tax return and on Foreign Bank Account Report (FBAR) forms. In 2009, when the IRS introduced its Offshore Voluntary Disclosure Program (OVDP), she joined the program…

New York State Bar Association Proposes OVDI Changes to IRS

- By : P. Patel

…evaluate the willfulness of every taxpayer who wishes to participate in the 2009 OVDP or the 2011 OVDI and that is why the Services has created a mechanism for taxpayers…

Foreign Account Tax Compliance Act (FATCA): More Information Sharing Agreements Expected

- By : P. Patel

…concerned about FATCA’s far reaching implications. As a result, Taxpayers with undisclosed foreign accounts should consult a competent tax lawyer and consider participating in the 2012 OVDP program. Although the…

Beware: IRS Form 8938 Statement of Specified Foreign Financial Assets

- By : P. Patel

…the applicable reporting requirements to assist them. Taxpayers with undisclosed foreign accounts should also consider participating in the 2012 OVDP. Although the 2012 OVDP penalty regime may seem harsh for…

IRS Has New Procedures for Scrutinizing Quiet Disclosures

- By : P. Patel

…“Quiet Disclosures” whereby IRS “campuses that receive amended tax returns reporting foreign attributes to forward them to the Quiet Disclosure Coordinator in OVDP for review.” Further, the IRS has a…

ABA Conference with Government Officials

- By : P. 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…

Received a FATCA Letter from Your Foreign Bank?

- By : P. Patel

…Accounts (FBAR) and a 1040 personal return, and whether the individual has availed himself or herself of the Offshore Voluntary Disclosure Program (OVDP) administered by the IRS to resolve tax…

Federal District Court Holds that FBAR Penalties in Excess of $100,000 is Unlawful

- By : P. Patel

…are currently considering OVDP should take this holding into account in the decision-making process, as the penalties for “willful” failures may not be as onerous as previously thought (however, possible…

Opting Out of the OVDI Program: Argue for No Penalty and a Warning Letter

- By : P. Patel

The revised IRS OVDP FAQs offer helpful guidance on the opt-out option. The newly revised FAQs illustrate the pros and cons of opting out with examples. Depending on the circumstances,…

IRS Announces Penalty Mitigation for Smaller US Taxpayers Living Abroad

- By : P. Patel

…not force everyone through the OVDI/OVDP programs. Yesterday, the IRS today announced a plan to help U.S. citizens residing overseas, including dual citizens, catch up with tax filing obligations and…

No tax = No Passport?

- By : P. Patel

…taxpayers including those who default on installment agreements, including those who may default on payments under the Offshore Voluntary Disclosure Initiative (OVDI or OVDP). The legislation (in its current form)…

Eleven foreign financial institutions to share their US customer account information

- By : P. Patel

…penalties grows greater as the IRS and Department of Justice complete more bank-investigations and as foreign banks continue to co-operate with US government officials. Offshore Voluntary Disclosure Program (OVDP) On…

HSBC officially provides information on clients having accounts in India to the US Department of Justice and IRS

- By : P. Patel

…with its branches in India. Last month, the Internal Revenue Service opened its Offshore Voluntary Disclosure Program (OVDP) to encourage more taxpayers with assets in undeclared foreign bank accounts to…

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

- By : P. Patel

…IRS has reportedly revoked pre-clearance letters authorizing taxpayers to participate in the OVDP, even though some had already made disclosures, filed returns, and paid taxes and penalties in reliance on…

Categories

Recent Posts