Search Results for: streamlined filing compliance procedures
Consequences of Filing False Streamlined Filings
…three years in prison. These cases show that taxpayers should be very careful in making a complete and correct Streamlined disclosure to the IRS. Advisors counseling taxpayers on Streamlined Procedures…
Citizenship renunciation fee increases as American expatriates flee FATCA
…retaining the right of residence in the USA. Our firm presented an informational webinar on the new Streamlined Filing Compliance Procedures available to many expats. Materials from the webinar can…
Top myths of US tax compliance for Foreign Accountholders
…has major penalties. However, the IRS has modified one of its amnesty programs, the Streamlined Offshore Filing Procedures, to eliminate late filing and FBAR (Foreign Bank Account Report) penalties. Under…
Denied access to or withdrew from the IRS Offshore Voluntary Disclosure Program (OVDP)?
…including examination and letters. Taxpayers who receive the letter have three options for complying. Option #1 is to make a submission under the Streamlined Filing Compliance Procedures (HERE) if they…
IRS announces an update to its Voluntary Disclosure Practice Preclearance Request and Application
…Criminal Investigation Voluntary Disclosure Practice IRM 9.5.11, Investigative Process – Other Investigations IRM 4.63.3, Withholding and International Individual Compliance – Offshore Voluntary Disclosure Program, Streamlined Filing Compliance Procedures and Voluntary…
New Webinar: Resolving International Tax Compliance Disputes: FBAR Controversy, Penalties, Appeals, Form 3520/3520-A, Form 5471
…and manage international tax compliance disputes thoroughly. Listen as our panel explains the most complex aspects of international tax compliance, including FBAR filing and reporting requirements, navigating assessments and litigation, the…
Full Analysis of Updated 2012 OVDP Program
…help US citizens living abroad who have not been filing their tax returns to become current with their filing obligations if they owe little or nothing in back taxes. The…
New IRS practice unit: “Substantial compliance” doctrine, international information return penalties
…practice unit webpage (release date of June 19, 2017). Substantial compliance doctrine International information returns must be substantially complete in order for the filer to have met its filing requirement….
Beware: IRS Reminds Taxpayers of FBAR Deadline
…FBAR requirement. The FBAR filing requirement is not part of filing a tax return. The FBAR Form 114 is filed separately and directly with FinCEN. FBAR filings have surged in…
IRS Updated Voluntary Disclosure Practice is a Game-Changer
…change other IRS programs, such as the IRS Streamlined Compliance Procedures (for non-willful US persons) including the popular Streamlined Domestic Offshore Procedures and Streamlined Foreign Offshore Procedures. The Updated VDP…
What Client Tax Advisors Should Do About the New Corporate Transparency Act
…Client Acceptance and Engagement Procedures: Implementing procedures to identify clients requiring CTA compliance and the specific portions applicable is crucial. Documentation: Maintaining detailed documentation of client interactions, decisions, and representations…
Swiss Government and US Government Announce New Program for Cooperation and Disclosure by Swiss Banks
…financial accounts outside of the United States (referred to collectively as the OVD Initiatives), incorporating definitions, due diligence procedures and compliance program approaches contained in the Foreign Account Tax Compliance…
What is a “FATCA Compliance Certificate”?
…Certificate. Technically, there is no FATCA Compliance Certificate, per se. Practically speaking, a FATCA Compliance Certificate simply refers to that indicates that the foreign account has been properly reported to…
New IRS Enforcement Letters Warn of Cryptocurrency Non-Compliance
…Virtual Currency Compliance campaign to address tax noncompliance related to the use of virtual currency through outreach and examinations of taxpayers. The IRS will remain actively engaged in addressing non-compliance…
IRS Publishes Useful Chart Outlining Compliance Options for Offshore Assets
…risk of being examined and potentially criminally prosecuted for all applicable years.” The IRS is contradicting itself. Also the IRS states elsewhere in its new New Filing Compliance Procedures for…
Make Sure You have Filed FATCA Compliance Certifications
…complete a “FATCA Compliance Certificate”. The reason for the request is that India and the US signed an agreement to implement the Foreign Account Tax Compliance Act (FATCA), which allows…
What Is The Difference Between the SDOP and the Current OVDP program?: Willfulness
…needs to be prepared to defend filing a SDOP and be able to demonstrate their non-willfulness and show there was no fraud. Nonwillfulness certification In the streamlined procedures, taxpayers must…
IRS Releases FAQs for the Delinquent International Information Return Submission Procedures
The IRS recently released frequently asked questions for the Delinquent International Information Return Submission Procedures (available here). The IRS now states that these procedures are available to taxpayers even if…
New EZPASS OVDP Without Any Penalties for Non-Resident U.S. Taxpayers
Yesterday, as expected, the IRS announced its new New Filing Compliance Procedures for Non-Resident U.S. Taxpayers that taxpayers presenting “low compliance risk” should file delinquent tax returns, including delinquent information…
Upcoming live video webinar: “FBAR and U.S. Tax Reporting: Compliance Requirements for Foreign Assets”
…delinquent international information return submission procedures and the delinquent FBAR submission procedures? When does a taxpayer qualify for these procedures? How should tax advisers best navigate the disclosure program requirements?…
The Teeth of the Foreign Account Tax Compliance Act (FATCA)
…plus simplified procedures to identify the FATCA status of preexisting entity accounts. New Accounts. FFIs will be able to use their existing customer intake procedures, including the usual data collected…
New FBAR FIling Deadline Law Signed
…by the differences in the filing dates. There were many instances of individuals that realize they had a filing responsibility on the June 30th deadline. Those taxpayers were usually stunned…
New Leak of Offshore Accountholders Highlights the Need to Clean Up
…the OVDP, and the newer streamlined procedures. The OVDP remains the safest and most foolproof program, with amnesty even for willful acts. But for those with the right facts, the…
IRS Announces Penalty Mitigation for Smaller US Taxpayers Living Abroad
…is made on a timely basis. The streamlined procedures will be made available to resolve low compliance risk situations even though this election was not made on a timely basis….
Welcome news from IRS for late Form 3520 penalties
On its website, the IRS has announced that it has retired its Form 3520/3520A compliance campaign. In welcome relief for taxpayers, the IRS also indicates in updated IRM procedures that it…
The IRS Large Business and International division (LB&I) has announced a new Post OVDP Compliance enforcement campaign
…offshore bank accounts, as a result, they suggested the campaign. The IRS Post OVDP Compliance enforcement campaign goal is to improve return selection, identify issues representing a risk of non-compliance,…
Details of the Delinquent International Information Return Submission Procedures (DIIRSP)
…International Information Return Submission Procedures if the IRS does not accept the explanation of reasonable cause. The longstanding authorities regarding what constitutes reasonable cause continue to apply, and existing procedures…
FATCAts
…institution must implement, and certify compliance with, complex customer identification procedures. If any American clients are identified, the financial institution must send information regarding those clients to the IRS. Specific…
IRS examines jewelry, precious stones and metals businesses for compliance
…Form 8300 compliance. This audit is very much like a tax audit; the IRS checks records to look for receipt of cash payments that required filing of the 8300 form….
FBAR Reforms Recommended
…the FBAR filing deadlines to the new April 15 date, update the filing exemption for officers and employees with signature authority but no financial interest, and require filers with 25…