IRS Announces New Clarifying FAQs for Streamlined Offshore Compliance Program

- By : Parag Patel

…partial interest. The IRS will apply the principles announced in OVDP FAQs 31 through 33, 35.1, and 38 through 41. This interestingly may be the first time where the IRS

IRS Form 8938 and the Offshore Voluntary Disclosure Program (OVDP)

- By : Parag Patel

…a significant tool for the IRS to identify the scope of international tax non-compliance of a given U.S. taxpayer. The reason why Form 8938 is so useful for the IRS

A solution in a tough tax season: the IRS Streamlined Offshore Procedures

- By : Parag Patel

…may be made on one of the following forms initially released by the IRS in August 2014: For U.S. taxpayers residing in the U.S. – IRS Form 14654: Certification by…

New IRS practice unit: “Substantial compliance” doctrine, international information return penalties

- By : Parag Patel

…particularly Form 5471. The IRS recently released a new International Practice Unit (“IPU”) on failures to file form 5471. IPUs are meant to act as a guide for IRS examiners…

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

- By : Parag Patel

…dollars. The IRS has also pursued criminal charges leading to billions of dollars in criminal fines and restitutions. The IRS remains committed to stopping offshore tax evasion wherever it occurs….

New IRS Voluntary Disclosure in 7 Steps

- By : Parag Patel

The following are the seven steps of the new updated IRS voluntary disclosure process: A taxpayer will make a voluntary disclosure preclearance request using IRS Form 14457 to IRS Criminal…

IRS collects over $5 billion in its its offshore voluntary disclosure programs

- By : Parag Patel

…those hiding assets offshore,” said IRS Commissioner Doug Shulman. “People are finding it tougher and tougher to keep their assets hidden in offshore accounts.” Shulman added the IRS OVDPs have…

The New IRS Voluntary Disclosure Practice: Not a Good Deal for Noncompliant Taxpayers

- By : Parag Patel

…Office of Appeals. The VDP does not impact the existence of the IRS’ Streamlined filing compliance procedures. The Advantages and Disadvantages of the IRS New Voluntary Disclosure Practice: Advantages: Avoidance…

Finally: IRS Reminds Those with Foreign Assets of U.S. Tax Obligations

- By : Parag Patel

…to address the IRS’ alleged shortcomings in educating taxpayers with foreign accounts. As a result, the IRS issued IR-2013-54 on May 23, 2013 which is provided below. WASHINGTON — The…

New IRS Relief for Taxpayers Experiencing COVID-related Difficulties

- By : Parag Patel

The IRS has announced new initiatives to help taxpayers experiencing Covid-related difficulties (which probably applies to most people) who have unpaid federal tax liabilities. Specifically, the IRS has announced the…

HSBC and NRI Bank Accounts: Could It Spread to Other Banks?

- By : Parag Patel

…rule, the IRS doesn’t comment on ongoing investigations”. On April 7, US authorities sought an order from a federal court in San Francisco, authorising the US IRS to request for…

Analysis of the new 2012 Offshore Voluntary Disclosure Program (OVDP)

- By : Parag Patel

…going forward, the IRS cautioned. For example, the IRS may increase penalties in the program for all or some taxpayers or defined classes of taxpayers—or decide to end the program…

IRS offers tax opportunity to Americans living abroad

- By : Parag Patel

…secret offshore accounts that they have knowingly failed to disclose to the IRS. An IRS statement said the new guidelines were for “low compliance risk” taxpayers, generally people who have…

India Expected to Sign FATCA Agreement Tomorrow

- By : Parag Patel

…shortly publish regulations for implementation of FATCA. Who is Reported? Many Indian financial institutions have already registered on the IRS’s FATCA Registration Portal. The IRS has published a searchable list…

Streamlined Filing Compliance Procedure’s New Revisions to Streamlined Foreign Offshore Procedures (SFOP)

- By : Parag Patel

…February 2016, the IRS revised Form 14653 to require more disclosure. Now the IRS also instructs the taxpayer to: Include the whole story including favorable and unfavorable facts. Specific reasons,…

Delinquent or unfiled IRS Form 5471

- By : Parag Patel

IRS Form 5471 is a form required to be filed by US owners of foreign corporations. The form and filing requirements are complicated, and the penalties and consequences for non-filing…

New Post-OVDP IRS Voluntary Disclosure Procedures Announced

- By : Parag Patel

…disclosures (both domestic and offshore) received by the IRS after the closing of the OVDP. The new procedure updates the old Voluntary Disclosure Practice of the IRS to provide taxpayers…

IRS Revises Delinquent International Information Return Submission Procedure (DIIRSP)

- By : Parag Patel

…not under a civil examination or a criminal investigation by the IRS and have not already been contacted by the IRS about the delinquent information returns should file the delinquent…

Beware: India to sign FATCA agreement with US for sharing of information

- By : Parag Patel

…U.S. Internal Revenue Service (IRS). The agreement would provide the Internal Revenue Service (IRS), access to details of all offshore accounts and assets beyond a threshold limit held by Americans…

IRS’ New “Dirty Dozen” list of tax scams

- By : Parag Patel

…of several typical IRS enforcement and compliance priorities, but the IRS indicated that a wholly separate enforcement and compliance priorities list is forthcoming.  Some selected new scams include: Senior Fraud:…

Government Report Advises IRS to Increase Awareness of Offshore Account Rules to Help Immigrants

- By : Parag Patel

…not targeted outreach efforts to new immigrants, the GAO’s report said. “Obtaining information on how taxpayers found out about IRS’s offshore voluntary disclosure programs could help IRS better identify populations…

Details of the Streamlined Foreign Offshore Procedures (SFOP)

- By : Parag Patel

…(SDOP) or the Streamlined Foreign Offshore Procedures (SFOP). This article focuses on the SFOP. The Internal Revenue Service (IRS) recently modified the non-willfulness certification form that individual taxpayers must submit…

IRS Warning Letter Warns Foreign Business Owners About Section 965 Transition Tax Enforcement

- By : Parag Patel

The IRS has recently begun sending “soft letters” (warning letters) to U.S. taxpayers owning foreign companies about IRC Section 965 transition tax compliance. In July 2020, The IRS Large Business…

Taxpayer’s Beware: Proving Non-Willful Conduct in the new IRS Streamlined Filing Compliance Procedures

- By : Parag Patel

…reasons, provide the individual reasons for each spouse separately in the statement of facts.” See the “non-willful” certification statement available at http://www.irs.gov/pub/irs-utl/CertUSResidents.pdf . Advocacy is required to affirmatively and persuasively…

Internal Revenue Service announces new International Data Exchange Service: The Beginning of Information Sharing

- By : Parag Patel

…and have a global intermediary identification number (GIIN) that appears on the IRS FATCA FFI list. The IRS has published a searchable list of financial institutions. The FFI List Search…

IRS Publicizes and Celebrates OVDI Success

- By : Parag Patel

…“have provided the IRS with a wealth of information on various banks and advisors assisting people with offshore tax evasion, and the IRS will use this information to continue its…

IRS Reminds U.S. citizens and dual citizens about U.S. filing requirements

- By : Parag Patel

In a fact sheet (IRS FS-2011-13) released last week, the IRS reminded U.S. citizens and dual citizens of the United States and foreign countries who live abroad about U.S. filing…

More Tax Complexity: New Form 8938

- By : Parag Patel

IRS’ initial warning. Additionally, the IRS may apply a 40% penalty on the taxes from non-disclosed assets. Unlike many US taxpayer tax matters, the filing requirements leave little guess work….

How Will the IRS Find Out By Your Foreign Account? Let’s Count the Dozens of Ways

- By : Parag Patel

…under investigation by IRS and Department of Justice G. 110 clients turned over to IRS by Swisspartners If you have risk of discovery of tax non-compliance, you must seek the…

New FATCA Enforcement Expected

- By : Parag Patel

IRS has permitted numerous nations to benefit from having status as IGA, even if they did not have a finalized IGA in force. In IRS Announcement 2016-17, however, the IRS