Search Results for: penalties
Swiss Banks’ Deadline to Disclose Information is Extended
…programme requires the category two banks to hand over some previously hidden information and face penalties equivalent to up to 50 percent of the assets they managed on behalf of…
Watch Out: IRS Audits of ERC Claims Expected
…may request other documents. You should never hide information from the IRS, but if you’re uncomfortable with an auditor’s request, contact a tax attorney for guidance. Penalties for Failing ERC…
Government Report Advises IRS to Increase Awareness of Offshore Account Rules to Help Immigrants
…offering a reduced risk of criminal prosecution and lower penalties than if the unreported income was discovered by one of IRS’s other enforcement programs. Those with offshore penalties greater than…
Opting-out of the Offshore Voluntary Disclosure Initiative: FBAR Penalty Mitigation Guidelines
…Violations Occurring After October 22, 2004 The Bank Secrecy Act (BSA) allows the Secretary of the Treasury some discretion in determining the amount of penalties for violations of the FBAR…
Details of the Delinquent International Information Return Submission Procedures (DIIRSP)
…Statement of Specified Foreign Financial Assets No penalties are applied if there is reasonable cause for the failure to file the information form and the IRS agrees. Reasonable Cause is…
The New DIIRSP: I like the old better
…necessary for taxpayers to respond to specific correspondence and submit or resubmit reasonable cause information.” These penalties could include penalties for failure to timely report or pay tax, as well…
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….
More Tax Complexity: New Form 8938
…accounts. Penalties Ignorance is not bliss when it comes to taxes, and there are penalties for failing to file the appropriate forms by the appropriate date. Each penalty is levied…
IRS Notices for OVDI Program
When the IRS receives payment with amended tax returns for taxes, interest and penalties, the IRS may misapply the payment. This results in IRS notices. Reminiscent of the mistakes of…
All the Many FBAR Late Filing Procedures
…a U.S. taxpayer may choose to pay a 5% Title 26 Miscellaneous Offshore Penalty instead of other delinquent FBAR and FATCA penalties. Our firm has successfully filed more than 300…
New Favorable Court Decision: One penalty (not multiple) applies for late FBAR filing
…simply an international information reporting form. The penalties for failing to file an FBAR, or for filing a false FBAR, are extremely high: $100,000 or 50 percent of the balance…
What Client Tax Advisors Should Do About the New Corporate Transparency Act
…must comply with the CTA by January 1st, 2024, by filing BOI reports with FinCEN. Failure to comply can incur significant penalties, including: Financial penalties: $500 per day of non-compliance, up to…
IRS Official Provides Insights for the new IRS Streamlined Compliance Procedures
…streamlined procedures so both U.S. and non-U.S. residents who certify their tax noncompliance was non-willful can qualify for 5% or zero penalties. At the same time, the IRS said it…
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…
IRS Releases New IRS 2022 FBAR Fact Sheet
…FBAR Submission Procedure (or DFSP), which our office has successfully utilized hundreds of times to cure delinquent FBARs and immunize clients from penalties. Nonethless, the new IRS 2022 FBAR Fact…
Received a FATCA Letter from Your Foreign Bank?
…qualifying financial institution may be required to submit this information to the IRS or face significant fines and penalties. Understanding the agreements in effect in your jurisdiction can help you…
New IRS Voluntary Disclosure in 7 Steps
…interest and penalties for the disclosure period. In case of lack of taxpayer cooperation, the IRS examiner can expand the years of the voluntary disclosure and/or assess more penalties. Taxpayers…
Employers Must Re-examine Employee Retention Credit (ERC) Claims
…improper claims. Options for Employers with Incorrect Claims ERC Voluntary Disclosure Program (Deadline was March 22, 2024; may be extended): Repay 80% of the incorrect ERC, with reduced penalties and…
Reasons to Opt Out of the 2011 OVDI Program
…2012) noting that $1,255,567 in willful and nonwillful penalties plus $1,671,518 in negligence penalties were assessed against taxpayers who opted out of the 2009 OVDP in 186 closed cases. Moreover,…
IRS Updated Voluntary Disclosure Practice is a Game-Changer
…documents until an IRS agent is assigned to the case. Other changes are more substantive, including changes to the disclosure period and penalties. The new Updated VDP Procedures DO NOT…
IRS Guidance Targets Cash Reporting in the Cannabis Industry
…Non-Compliance Failure to correctly file Form 8300 can lead to substantial penalties, especially if the IRS determines the noncompliance was intentional. Historically, the IRS has prioritized compliance over using penalties…
NJ Division of Taxation Offers Offshore Voluntary Compliance Initiative
…that come forward voluntarily and disclose their tax obligation by September 30, 2011 will avoid all civil penalties, including the 50% civil fraud penalty. However, the 5% late payment penalty…
Swiss Banks are Pressuring Customers to Disclose
…pay stiff penalties up to 50% of the balance of the accounts to obtain legal closure. Swiss banks hope to reduce their own penalties by pressuring their clients to confess….
2011 Offshore Voluntary Disclosure Initiative Frequently Asked Questions (FAQs) and Answers
…the statute of limitations for assessing tax (including tax penalties) and to assess FBAR penalties. For additional information, contact Parag Patel of Patel Law Offices at 732-623-9800 or visit us…
National Taxpayer Advocate Delivers Annual Report to Congress that Criticizes Offshore Voluntary Disclosure Programs
…Program Inequities. The report describes the evolution of the OVD program and the disproportionate penalties it says were often imposed, particularly with respect to unrepresented taxpayers. The IRS changed the…
IRS list of “dirty dozen” tax scams
…penalties. At the TOP of the Dirty Dozen for 2011: Hiding Income Offshore The IRS aggressively pursues taxpayers involved in abusive offshore transactions as well as the promoters, professionals and…
IRS Reminds U.S. citizens and dual citizens about U.S. filing requirements
…and does not impose a tax, although failure to file it can incur penalties. Non-willful failure to file may be penalized by up to $10,000 per violation, unless the failure…
IRS Announces New 2012 Offshore Voluntary Disclosure Program (OVDP)
…file all original and amended tax returns and include payment for back-taxes and interest for up to eight years as well as paying accuracy-related and/or delinquency penalties. Under the new…
Beware: IRS Form 8938 Statement of Specified Foreign Financial Assets
…year. Married filing jointly living abroad: $400,000 on the last day of the year or $600,000 anytime during the year. There are significant civil and criminal penalties for failure to…
Another Local New Jersey client of HSBC India Pleads Guilty
…his gain from the offense, together with the costs of prosecution. Gupta agreed to file true and accurate tax returns and to pay to the IRS all taxes and penalties…