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Another Customer with Unreported Offshore Bank Accounts Pleads Guilty

21 January, 2015

George Landegger, CEO of pulp and paper company, pleaded guilty last week in New York to a federal charge of failing to file a required report to the IRS about the account. He admitted that

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

17 January, 2015

The Internal Revenue Service announced this week the opening of the International Data Exchange Service (IDES) for enrollment.  Financial institutions and host country tax authorities will use IDES to securely send their information reports on

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National Taxpayer Advocate Delivers Annual Report to Congress that Criticizes Offshore Voluntary Disclosure Programs

14 January, 2015

National Taxpayer Advocate Nina E. Olson today released her 2014 annual report to Congress, which expresses concern that taxpayers this year are likely to receive the worst levels of taxpayer service since at least 2001

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New IRS Subpoenae and IRS Data Mining Expected

26 December, 2014

Last week a federal judge approved the IRS issuing “John Doe” summonses requiring FedEx, DHL, UPS, and numerous other intermediaries to produce information about U.S. taxpayers who used Sovereign Management & Legal Ltd. for offshore

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News from the 2014 Criminal Fraud and Tax Controversy Conference

22 December, 2014

We just returned last week from attending the Criminal Fraud and Tax Controversy Conference in Las Vegas, sponsored by the American Bar Association Section of Taxation where many government officials were in attendance. Below are

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IRS Releases Training Documents on Offshore Voluntary Disclosure Program

2 December, 2014

last month the IRS released more than 6,500 pages from the Internal Revenue Service on the agency’s Offshore Voluntary Disclosure Program and how it trains its agents. The documents included material used in training IRS personnel in

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IRS Streamlined Filing Compliance Procedures Seminar

23 November, 2014

The Internal Revenue Service announced major changes in its offshore voluntary compliance programs, providing new streamlined filing compliance procedures to help both taxpayers residing overseas and those residing in the United States. The streamlined filing

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IRS Announces New Clarifying FAQs for Streamlined Offshore Compliance Program

25 October, 2014

The IRS updated its streamlined offshore compliance program to provide procedures taxpayers residing both inside and outside the United States should use to participate in the program. The streamlined offshore compliance program is for taxpayers whose failure to

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IRS Releases FAQs for the Delinquent International Information Return Submission Procedures

19 October, 2014

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 they have unreported income. See below

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New Report: Delinquent Taxpayers Could be Identified at US Border Crossings

19 October, 2014

The Internal Revenue Service’s collection efforts need to be improved to make sure that delinquent taxpayers residing in foreign countries comply with their U.S. tax obligations, according to a new government report. The report, from the

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IRS Clarifies Requirements for Streamlined Filing Procedures

15 October, 2014

Our office has received many inquiries from taxpayers interested in the Streamlined Filing Compliance Procedures with the new lower penalty.  However IRS guidance and instructions was unclear and ambiguous in certain areas.  Last week, on

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OVDP New Forms Announced by IRS

10 October, 2014

The IRS has simplified the process of entering the OVDP Program by issuing the following forms: Form 14457 – Offshore Voluntary Disclosure Letter Form 14454 – Offshore Voluntary Disclosure Program Letter Attachment The new forms (the old

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