Search Results for: voluntary disclosure programs
American Citizens Abroad (ACA) writes letter to IRS Commissioner regarding unfair offshore asset treatment
…by IRS examiners under the 2009 offshore voluntary disclosure program (OVDP). Commissioner Shulman had until the end of January 2012 to answer Olson’s Directive, but has chosen not to. ACA’s…
New IRS guidance Announced for IRS Streamlined Offshore Procedures.
…programs require U.S. taxpayers to certify that their prior non-compliant conduct was non-willful. The IRS earlier this month announced new guidance under the Streamlined programs. The new guidance announces three…
The Tax Heat is On
…in the IRS’s long-running Offshore Voluntary Disclosure Program (OVDP). This penalty is based on the highest account balance measured over up to eight years. Whether a taxpayer’s conduct is non-willful…
IRS expands use of Subpeonas
…for suspecting tax evasion has come from two main sources: various offshore voluntary disclosure programs and whistleblowers. The summonses against Butterfield and CIBC FirstCaribbean were prompted by a number of…
New IRS IRM with Updated Streamlined Filing Compliance procedures
…income or foreign assets, generally, foreign bank accounts. In part, the revised procedures address concerns of taxpayers and their professional advisers that the traditional offshore voluntary disclosure programs (OVDPs) often…
Reasonable Cause Defense Denied: FBAR Penalties Assessed by Court
…If taxpayers are non-compliant with their foreign asset and income reporting requirements, they should consider getting qualified tax legal advice and considering applying to one of IRS’ voluntary disclosure programs….
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….
The Misunderstood Extension of time to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR)
…etc. Individuals that have failed to file such forms should immediately seek guidance from an experienced tax attorney to explore voluntary disclosure programs, which have reduced penalties or no penalties….
FBARs from Wuhan
…unexpected future complications. All advisors should routinely ask about clients’ foreign accounts. There are various voluntary disclosure programs to correct past non-filings and noncompliance issues to affirmatively address such problems….
Are You Ready For New FATCA Enforcement in 2020?
…non-compliant with their foreign asset and income tax form reporting requirements, they should consider getting qualified tax legal advice and considering applying to one of the IRS’ voluntary disclosure programs….
US Court finds non-willful FBAR penalty not limited to $10,000 per year
…ruling, taxpayers with unreported foreign financial accounts should consider entering one of the IRS’ voluntary disclosure programs, such as the Streamlined Domestic Offshore Procedure. Noncompliant taxpayers are strongly recommended to…
Foreign Retirement Plans: New IRS Exemption from Required Information Reporting on Forms 3520 and 3520-A
…they are fully compliant with all U.S. income tax return filing and reporting requirements because compliance will ultimately determine their eligibility for penalty relief in various favorable voluntary disclosure programs….
Streamlined Filing Compliance Procedure’s New Revisions to Streamlined Domestic Offshore Procedures (SDOP)
…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,…
New IRS Subpoenae and IRS Data Mining Expected
…2011, report by the Treasury Inspector General for Tax Administration (TIGTA), IRS’s data-mining software is called the E-Trak Offshore Voluntary Disclosure system. Since 2009, more than 33,000 taxpayers have contributed…
IRS list of “dirty dozen” tax scams
…with their taxes. The new voluntary disclosure initiative will be available through Aug. 31, 2011. The IRS decision to open a second special disclosure initiative follows continuing interest from taxpayers…
Appeals of penalties imposed during the Offshore Voluntary Opt-Out
…tax disputes internally in a way that foments future voluntary taxpayer compliance with the tax laws. Appeals officers have greater authority and flexibility in deciding cases than auditors. Their competence…
IRS Publishes Useful Chart Outlining Compliance Options for Offshore Assets
…on offshore enforcement efforts and related disclosure programs has raised awareness among many U.S. citizens about tax filing and information reporting obligations”. For some of our clients, who are panicking…
IRS reminds those with foreign assets about U.S. tax obligations
…to them. The form is only available through the BSA E-Filing System website. Reminder: IRS to end Offshore Voluntary Disclosure Program The Offshore Voluntary Disclosure Program will close on Sept….
IRS Revises Delinquent International Information Return Submission Procedure (DIIRSP)
The IRS revised its Delinquent International Information Return Submission Procedure (DIIRSP) last week. The DIIRSP provided an alternative 0% penalty voluntary disclosure process to taxpayers other than the Offshore Voluntary…
Explore the OVDI opt-out option: Argue for Penalty Mitigation
…of the voluntary disclosure initiative and allow us to demonstrate the absence of willfulness and avoid the normal FBAR penalty regime. We have been aggressively pursuing OVDI opt-outs for some…
IRS announces two new intriguing targeted enforcement campaigns
…return selection, identify issues representing a risk of noncompliance, and make the greatest use of IRS limited resources. The IRS initially launched the Offshore Voluntary Disclosure Program (OVDP) in 2009…
Correcting Common FBAR Errors
The IRS offers four options to fix FBAR mistakes. Participation in the two formal disclosure programs is permitted only if the funds held in the foreign financial account(s) are from…
Hiding Money or Income Offshore Among the “Dirty Dozen” List of Tax Scams for the 2015 Filing Season
…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…
Happy Birthday Streamlined Filing Compliance Procedure!
…the disclosure of foreign assets. SFCP has two sub-programs: one for US residents (Streamlined Domestic Offshore Procedures or “SDOP”) and one for non-US residents (Streamlined Foreign Offshore Procedures or “SFOP”)….
Details of the Streamlined Foreign Offshore Procedures (SFOP)
…meets the eligibility requirements, then the taxpayer may make a voluntary disclosure as part of the SFCP program. The SFOP requires the taxpayer to submit, in addition to filing any…
IRS Notices for OVDI Program
…“refunds” for 2007, because of the application of multi-year payments to that single year, and the IRS is issuing demands for payment for all other years of the voluntary disclosure….
New Court Case Limits the Reasonable cause exception to FBAR penalties
…were confirmed by the audit, the transfers triggered an investigation into the couple’s FBAR violations. Because of the audit, the couple were advised not to participate in a voluntary disclosure…
IRS Announces new OVDP Declines-Withdrawals Campaign
…the IRS Offshore Voluntary Disclosure Program. Entitled, “OVDP Declines-Withdrawals Campaign,” this area of focus involves taxpayers who have applied for the offshore voluntary disclosure program through the pre-clearance process, but…
IRS offers tax opportunity to Americans living abroad
…IRS tightened its policies in other ways on Tuesday, saying it might exclude from the voluntary disclosure program U.S. taxpayers with foreign accounts at foreign banks that have faced sanctions…
New Law’s Reporting Requirements Make It Very Likely That the IRS Will Now Know About Your Foreign Account
…expected that most foreign institutions will ultimately comply with these account disclosure requirements. Note also that FATCA imposes additional disclosure requirements (via a new Form 8938) on U.S. individuals with…