Search Results for: penalties
How to Avoid Employee Retention Credit (ERC) Scams
…penalties for erroneous claim for a refund (20%), penalties attributable to fraud (75%), or evasion of employment taxes (100%). Taxpayers always bear the burden of substantiating reasonable cause to avoid…
Numerous Criminal Prosecutions of Taxpayers with Unreported Offshore Accounts
…for a whistle-blower reward for the taxes and penalties collected as a result of his cooperation. United States v. Jeffrey Chatfield, 10-CR-4546 (S.D. Cal.): On November 17, 2010, Chatfield pleaded…
Foreign Proprietorship: Form 8858 Filing Requirement
…on the specifics of your situation. Form 8858 Penalties A $10,000 penalty applies for the failure to timely file Form 8858 or if the Form 8858 is incomplete or inaccurate…
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…
Streamlined Filing Compliance Procedure’s New Revisions to Streamlined Domestic Offshore Procedures (SDOP)
…NOT subject to other various penalties (e.g., failure-to-file and failure-to-pay penalties, accuracy related penalties, information return penalties or FBAR penalties). Taxpayers in the SDOP must submit Form 14654 (Certification by…
Streamlined Filing Compliance Procedure’s New Revisions to Streamlined Foreign Offshore Procedures (SFOP)
…U.S. Person Residing Outside of the U.S. (Form 14653). Taxpayers who enter the SFOP are NOT subject to any penalties (i.e., failure-to-file and failure-to-pay penalties, accuracy-related penalties, information return penalties,…
The New IRS ERC Voluntary Disclosure Program
…potential civil litigation, penalties & interest. Under the ERC VDP, if the IRS paid interest on the employer’s ERC refund claim, the employer is not required to repay that interest….
IRS Announces New Statistics Regarding Voluntary Disclosures
…the streamlined procedures may be subject to IRS examination, additional civil penalties, and even criminal liability, if appropriate. Taxpayers who are concerned that their failure to report income, pay tax,…
Streamlined Procedures for U.S. Taxpayers Residing In the United States
…information return penalties or FBAR penalties. Even if returns properly filed under these procedures are subsequently selected for audit, no such penalties will be imposed unless the examination results in…
Details of the Streamlined Foreign Offshore Procedures (SFOP)
…(Form 14653). Taxpayers who enter the SFOP are NOT subject to any penalties (i.e., failure-to-file and failure-to-pay penalties, accuracy-related penalties, information return penalties, FBAR penalties, or a Title 26 miscellaneous…
Details of the Streamlined Domestic Offshore Procedures
…base). However, taxpayers who enter the SDOP are NOT subject to other various penalties (e.g., failure-to-file and failure-to-pay penalties, accuracy related penalties, information return penalties or FBAR penalties). Taxpayers in…
IRS Offshore Voluntary Disclosure Programs Continue to Burden “Benign Actors” and Damage IRS Credibility
…actors” who inadvertently violated the rules, requiring them to opt-in and then optout, and subjecting them to lengthy examinations and draconian civil and criminal penalties. In addition to criminal penalties,…
Frequent Scenarios in Offshore Voluntary Disclosures
…more and more resources on international tax evasion techniques and tax evasion careful reporting is a must to avoid penalties, including penalties for tax evasion, tax fraud and FBAR penalties….
Rare Supreme Court Ruling Favors Taxpayers!
…with foreign accounts. However, penalties are still very high for non-compliance. Noncompliant taxpayers are encouraged to use some of the voluntary disclosure programs with reasonable penalties to come into compliance….
New Jersey Enacts Tax Amnesty Bill
…late filing penalties; – cost of collection; – delinquency penalties; or – recovery fees. However, a taxpayer is required to pay any civil fraud or criminal penalties arising out of…
New Jersey Tax Amnesty program
…taxes or file past returns with no penalties and reduced interest. “We are pleased to offer taxpayers a chance at compliance and a fresh start through the New Jersey Tax…
Difference between Form 8938 and FBAR Requirements
Comparison of Form 8938 and FBAR Requirements Many holders of foreign financial assets must file two disclosure forms this year or else risk draconian penalties. They are Form…
Foreign Account Tax Compliance Act (FATCA) online registration program is launched
…to take before the Foreign Account Tax Compliance Act (FATCA), enacted in 2010, takes effect in July 2014 with steep penalties for firms that do not comply. FATCA requires foreign…
Swiss Government and US Government Announce New Program for Cooperation and Disclosure by Swiss Banks
…US criminal prosecution (often fatal irrespective of the merits or ultimate outcome) in exchange for detailed disclosures, the payment of financial penalties (in some instances), and various undertakings, to include…
New FATCA Enforcement Expected
…Tax Credit, you must timely file your U.S. income tax return. 3. Discovery of non-compliance means large penalties. Tax delinquency can result in a punitive monetary penalties and, in some…
IRS Launches Second Offshore Voluntary Disclosure Initiative After Successful Prosecution
…small account holders. 2. Participants must file all original and amended tax returns for up to 8 years and include payments for taxes, interest and accuracy related penalties. Patel believes…
Secret Swiss Bank Accounts are No Longer Secret
…agreeing to pay the U.S. Treasury billions of dollars in penalties and back taxes. As a result of UBS’ experience, many Swiss banks began coming forward with account information, or…
IRS Collects $10 Billion From Voluntary Disclosures of Foreign Assets
…tax obligations, paying more than $9.9 billion in taxes, interest and penalties since 2009. On top of that, an additional 48,000 taxpayers who have not willfully avoid paying taxes have…
“Willfulness” When Deciding Whether to Opt Out of 2011 OVDI
…to the taxpayer instructing the taxpayer to provide a written statement setting forth the facts of the case and a recommendation of the penalties that should apply. The election to…
Pandora’s Box Has Opened: Pandora Papers
…for non-compliance. The penalties for FBAR noncompliance are higher than the tax penalties ordinarily imposed for delinquent taxes. For non-willful violations it is $10,000 per account per year going back…
Forms 5471, 5472, 3520 Partial Penalty Relief Still Available for 2019 and 2020 Returns
IRS Notice 2022-36 provided relief for certain taxpayers from certain failure to file penalties and certain international information return penalties with respect to tax returns for tax years 2019 and…
New Unreported Offshore Assets case: Bad facts leads to bad results
…The facts of this case are bad and unfavorable to the taxpayer, hence the high penalties. Taxpayers with better facts can expect better results and avoid prosecution and high penalties….
IRS announces an update to its Voluntary Disclosure Practice Preclearance Request and Application
…and penalties. Taxpayers who did not commit any tax or tax-related crimes and wish to correct mistakes or file delinquent returns should consider other options available to comply with their…
How to Demonstrate Non-Willfulness Under The Streamlined Filing Compliance Procedures
…years as well as properly report any U.S. source income and deductions for each of the applicable tax years. For eligible U.S. taxpayers residing outside the United States, all penalties…
FBAR compared to Form 8938: Differences, Which to File, When to File, etc.
…after IRS notice of a failure to disclose, for a potential maximum penalty of $60,000; criminal penalties may also applyCivil monetary penalties are adjusted annually for inflation. For civil penalty…