New IRS guidance Announced for IRS Streamlined Offshore Procedures.

- By : Parag Patel

…have questions about the terms of the Streamlined Filing Compliance Procedures or completing Form 14654, you may contact the OVDP Hotline at 267-941-0020. The OVDP Hotline will not provide case-specific…

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

- By : Parag 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 : Parag 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 : Parag 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…

IRS Releases Training Documents on Offshore Voluntary Disclosure Program

- By : Parag Patel

…material used in training IRS personnel in the Offshore Voluntary Disclosure Program, determining program penalties and instructing IRS employees about the program. The purpose of the OVDP is for individuals…

New FinCEN Form 114 (FBAR) Filing Rules Announced

- By : Parag 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…

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…

New IRS internal procedure guidance for Streamline Filing Compliance Procedures

- By : Parag 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 : Parag 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 : Parag 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 : Parag 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 : Parag 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 : Parag 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…

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

- By : Parag 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 : Parag 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…

New IRS Subpoenae and IRS Data Mining Expected

- By : Parag 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…

Significant FBAR Penalties Upheld by Court

- By : Parag 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…

Helpful Non-willful FBAR penalty case decided by court

- By : Parag 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…

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

- By : Parag 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,…

New York State Bar Association Proposes OVDI Changes to IRS

- By : Parag 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…

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

- By : Parag 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…

Received a FATCA Letter from Your Foreign Bank?

- By : Parag 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…

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

- By : Parag 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…

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…

IRS Announces Penalty Mitigation for Smaller US Taxpayers Living Abroad

- By : Parag 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 : Parag 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 : Parag 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 : Parag 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…

Beware: IRS Form 8938 Statement of Specified Foreign Financial Assets

- By : Parag 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…

COURT AUTHORIZES SERVICE OF JOHN DOE SUMMONS SEEKING THE IDENTITIES OF U.S. TAXPAYERS WITH OFFSHORE ACCOUNTS AT CIBC FIRSTCARIBBEAN INTERNATIONAL BANK

- By : Parag Patel

…HSBC India accountholders seriously consider entering the IRS OVDP program for protection against civil (and criminal) penalties. Patel Law Offices is a law firm dedicated to helping clients resolve complicated…