Search Results for: voluntary disclosure programs
IRS Announces “Good Faith” 90 Day Extension of Voluntary Disclosure Deadline
The IRS said last week that it is making available to taxpayers a 90-day deadline extension to participate in the 2011 offshore voluntary disclosure initiative (OVDI). The extension would be…
Quiet or Silent Disclosure Commentary from the Government Accountability Office
…their offshore accounts without paying all the delinquent taxes, interest, and penalties required by the programs. In a quiet disclosure, taxpayers file amended tax returns for all or some of…
IRS Announces New Statistics Regarding Voluntary Disclosures
Since the initiation of the U.S. Internal Revenue Service’s (IRS) Offshore Voluntary Disclosure Program (OVDP) which originally began in 2009 and the Streamlined Filing Compliance Procedures first offered on September…
New offshore account disclosure law
…provisions. Increased disclosure of beneficial owners Reporting on certain foreign bank accounts. The Act imposes a 30% withholding tax on certain income from U.S. financial assets held by a foreign…
Parag Patel Esq. speaks at New Jersey Society of Certified Public Accountants (NJCPA) Annual Tax Seminar: “2022 Federal Tax Update and Latest Tax Controversy Hot Topics”.
…tax controversy. We will explore tax collection developments, penalty developments, new voluntary disclosure programs, the latest IRS audit campaign initiatives, and other hot topics in tax controversy. The New Jersey…
Parag Patel Esq. speaks at NJCPA Seminar ” Federal Tax Update and Latest Tax Controversy Hot Topics”
…with the latest developments in tax controversy. This session will explore tax collection developments, penalty developments, new voluntary disclosure programs, the latest IRS audit campaign initiatives and other hot topics…
Employee or Contractor?: The IRS’s New Voluntary Classification Settlement Program (VCSP)
…OVDI for foreign accounts and assets. Through these “voluntary” programs, the IRS has collected billions and is getting many taxpayers back into the IRS system in a major way. The…
New FinCEN Form 114 (FBAR) Filing Rules Announced
…the penalties can be overwhelmingly high, there have been a host of Voluntary Disclosure Programs offered by the IRS that can potentially reduce or even eliminate the penalties noted above….
U.S. Taxpayers at New Risk of Audit from OVDP Declines and Withdrawals Campaign
Last year, the US Treasury Inspector General for Tax Administration (TIGTA) released a report which assessed how well that IRS was managing the Offshore Voluntary Disclosure Program (OVDP). OVDP is…
For the First Time IRS Issues Information on 2011 Offshore Voluntary Disclosure Initiative (OVDI) in Hindi Language
In an effort to reach all taxpayers, including those ensnared in the pending HSBC subpoena to disclose customer names of non-resident indian customers with offshore accounts, the IRS has published…
Eleven foreign financial institutions to share their US customer account information
…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…
Frequent Scenarios in Offshore Voluntary Disclosures
I have frequently seen the following scenarios in working with clients to determine whether a offshore voluntary disclosure program filing (OVDP) is appropriate and how they should report foreign account….
The Risks of “Opting Out” of OVDI
Under the 2011 OVDI voluntary disclosure program, the penalties for failing to timely file Foreign Bank Account Reports, (FBAR’s) and the penalties for failure to file information returns (such as…
One Month Countdown: The Deadline is Nearing for U.S. Taxpayers with Undisclosed Accounts to Come Forward
The deadline to enter a complete submission into the 2011 Offshore Voluntary Disclosure Initiative (OVDI) is August 31, 2011, only one month remains and time is running out. The OVDI…
New Leak of Offshore Accountholders Highlights the Need to Clean Up
…to better analyze the taxpayers’ position and recommend one of the two programs to clean up their mess. Most importantly, account holders become ineligible to enter the voluntary disclosure programs…
High Penalties for failure to file an FBAR: Not Really Enforced (yet)?
…or multiple accounts could lead to complications. In such cases, there are several voluntary disclosure programs to cure late or non-filing of FBARs., which should be seriously considered and explored….
Expect new aggressive IRS targeted enforcement next year.
…identify and warn targeted taxpayers of certain problems with their returns to increase voluntary tax compliance via IRS voluntary disclosure programs. As a result, we anticipate increased enforcement next year…
2016 US Dept of Justice (DOJ) Tax Division: FBAR penalty collection cases
…disclosure programs that may offer no or more favorable penalties. We have provided a summary of interesting civil FBAR penalty enforcement cases below. However, first, some legal background for the…
Opt Out of OVDI Program Penalties to Get a Lower Penalty
Under the 2011 Offshore Voluntary Disclosure Initiative (OVDI) or 2012 Offshore Voluntary Disclosure Program (OVDP), the 2012 program gives no discretion to the IRS agents to reduce penalties. If a…
Streamlined Filing Compliance Procedure’s New Revisions to Streamlined Foreign Offshore Procedures (SFOP)
…disclosed foreign assets to the U.S. government. The IRS introduced SFCP in June 2014 as an alternative to its existing Offshore Voluntary Disclosure Program (OVDP), which was designed more for…
Method to Cure Delinquent or Incomplete Foreign Information Returns Without Penalties
Last year, the IRS announced its third offshore voluntary disclosure initiative. Like the earlier initiatives, the 2012 OVDP is designed to encourage taxpayers with unreported offshore accounts and assets to…
COURT AUTHORIZES SERVICE OF JOHN DOE SUMMONS SEEKING THE IDENTITIES OF U.S. TAXPAYERS WITH OFFSHORE ACCOUNTS AT CIBC FIRSTCARIBBEAN INTERNATIONAL BANK
…offshore accounts. Kiger’s declaration describes her review of the information submitted by more than 120 FCIB customers who participated in the IRS’s Offshore Voluntary Disclosure Program. According to the Kiger…
All the Many FBAR Late Filing Procedures
…program. To learn more about SFOP go to: https://patellawoffices.com/blog/planning-for-tax-minimization/details-of-the-streamlined-foreign-offshore-procedures-sfop/ IRS Voluntary Disclosure Program Between 2009 to 2018 there used to be a program called the Offshore Voluntary Disclosure Program for…
Instructions for New Streamlined Filing Compliance Procedures for Non-Resident, Non-Filer U.S. Taxpayers
…three years, in a manner similar to opting out of the Offshore Voluntary Disclosure Program. Taxpayers utilizing this procedure will be required to file delinquent tax returns, with appropriate related…
Should I close my foreign account?
…voluntary disclosure program and paying a 27.5 percent penalty on your highest account balance? At tax return filing time, should you check the box on Schedule B noting that you…
New IRS Disclosure Program Announced for Non-Resident Taxpayers: Streamlined Foreign Offshore Procedures
…The IRS has announced a Streamlined Foreign Offshore Procedures (SFOP), which will significantly alter all future voluntary disclosures. The SFOP is a game changer for non-resident and resident (who would…
Employers Must Re-examine Employee Retention Credit (ERC) Claims
…Incorrect claims bring penalties and potential audits. Get Help If you find errors in your ERC claims, consult a tax professional immediately to discuss the Voluntary Disclosure or Withdrawal programs….
IRS Publicizes and Celebrates OVDI Success
…Voluntary Disclosure Practice filings outside of OVDI. The IRS has detailed the terms of its existing traditional Voluntary Disclosure Practice in its Internal Revenue Manual (IRM) 9.5.11.9 (titled “TAX CRIMES…
The legal standard of “willfulness”: Opt out to avoid high penalties
…the government has had difficulty in establishing willfulness for the high draconian FBAR penalty. As a result, we often recommend some taxpayers to opt out of the voluntary disclosure initiative…
IRS Official Provides Insights for the new IRS Streamlined Compliance Procedures
Taxpayers who are in the Offshore Voluntary Disclosure Program to report their overseas assets can request the favorable penalty structure under newly expanded streamlined compliance procedures without giving up the…