Search Results for: voluntary disclosure programs
Silent Disclosure: The Qualified Amended Return (QAR)
…inaccurate tax return. First the QAR rule: Disclosures can be made on a qualified amended return. Treas. Reg. § 1.6664-2(c)(2). Amounts of tax reported on a qualified amended return will…
Swiss Bank Disclosure Round Up
A host of Swiss banks have signaled their readiness to work with U.S. officials in a crackdown on wealthy Americans evading taxes. Many more are expected to follow in the…
No More Delays for FATCA: Get Ready for Disclosure
The US Foreign Account Tax Compliance Act (FATCA) will definitely come into effect on 1 July this year with no possibility of further delay, according to officials of the US…
Estate Planning for Families with Special Needs Children
…life of their special needs child while maintaining the child’s enrollment in essential public benefits programs. These goals can be met through the use of a properly prepared special needs…
Solution: Streamlined Domestic Offshore Procedures
…accounts should fully explore some form of voluntary disclosure before it is too late and much more costly. Patel Law Offices has consulted with hundreds of clients regarding their offshore asset and income…
A solution in a tough tax season: the IRS Streamlined Offshore Procedures
…In summary, taxpayers with undisclosed offshore accounts should fully explore some form of voluntary disclosure before it is too late and much more costly. Our firm presented an informational webinar…
National Taxpayer Advocate Identifies OVDP Program as a Serious Problem
…the “one-size-fits-all” approach of the IRS Offshore Voluntary Disclosure Program (OVDP), and identified the OVDP program as a most serious problem requiring resolution. The Report states that the IRS discouraged…
Common Issues for US-India Tax Reporting
…amnesty programs, under which a previously non-compliant individual can become compliant and avoid potentially very high penalties or criminal prosecution. However these amnesty programs generally require the taxpayer to come…
Top myths of US tax compliance for Foreign Accountholders
…as the Foreign Tax Credit, are also available to offset US tax due. Myth #3: I’ll be forced to pay major penalties. This is false. The Offshore Voluntary Disclosure Program…
50% Penalty for Taxpayers Who Hold Accounts at a Bank Under Investigation
…seems to have gone up significantly. In summary, taxpayers with undisclosed offshore accounts should fully explore some form of voluntary disclosure before it is too late and much more costly….
Taxpayer’s Beware: Proving Non-Willful Conduct in the new IRS Streamlined Filing Compliance Procedures
…the IRS’s Offshore Voluntary Disclosure Program—for those who intentionally hid money abroad—must pay a much higher penalty: 27.5% of the account’s peak balance. Interest, other penalties and advisers’ fees can…
HSBC officially provides information on clients having accounts in India to the US Department of Justice and IRS
…with its branches in India. Last month, the Internal Revenue Service opened its Offshore Voluntary Disclosure Program (OVDP) to encourage more taxpayers with assets in undeclared foreign bank accounts to…
New Online System for Filing Your Report of Foreign Bank and Financial Accounts (FBAR)
…voluntary disclosure under the IRS’s Offshore Voluntary Disclosure Initiative (OVDI) and avoid or decrease penalties. The OVDI is open until August 31, 2011. FinCEN said it can only accept FBAR…
Foreign Account Penalties Are Unfair
…government is realizing the unfairness of the offshore penalties. In her June 30, 2011 Report to Congress, U.S. Taxpayer Advocate Nina Olson criticizes the IRS over its Offshore Voluntary Disclosure…
Opting-out or Opting-in of OVDI
…could be proved to not be “wilful”, and has also re-specified the conditions under which taxpayers making voluntary disclosures may qualify for a 5% offshore penalty. For example, that reduced…
File a Protective Claim for Refund for Possible OVDP Opt Out Cases
In 2009, the IRS had introduced an Offshore Voluntary Disclosure Initiative/Program (OVDI/OVDP). In following years, the program was reintroduced and revised. When it comes to addressing offshore filing deficiencies, several…
Swiss Banks’ Deadline to Disclose Information is Extended
…in the IRS Off-shore Voluntary Disclosure Program (OVDP) or seek to correct tax noncompliance through other avenues. The OVDPoffers an incentive for delinquent tax payers to disclose their offshore accounts….
HSBC India Customer New Indictment Uncovers More HSBC Details
…few of them have disclosed details of their accounts. In light of prosecution and summons, it is imperative that HSBC India accountholders seriously consider entering the IRS Voluntary Disclosure Practice…
The FinCEN Files Leak
…clients with offshore bank accounts want to know if they can repatriate their funds to the U.S. without taking any affirmative steps such as a voluntary disclosure on the theory…
OVDP New Forms Announced by IRS
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…
Penalty relief for International Information Forms 5471, 5472, and 8865
…any penalty. Note that the streamlined procedures are distinct from the IRS Criminal Investigation Voluntary Disclosure Practice (see IRM §9.5.11.9 (9/17/20), Voluntary Disclosure Practice), which is typically for willful taxpayers. Reasonable cause: The…
The IRS Large Business and International division (LB&I) has announced a new Post OVDP Compliance enforcement campaign
…and make the greatest use of IRS limited resources. The IRS launched the Offshore Voluntary Disclosure Program (OVDP) in 2009 to encourage compliance with foreign asset reporting. U.S. persons are…
New EZPASS OVDP Without Any Penalties for Non-Resident U.S. Taxpayers
…which in some cases may include more than three years, in a manner similar to opting out of the Offshore Voluntary Disclosure Program”. Opting may not be a bad situation….
Most Swiss banks participating in the US Department of Justice (DOJ) amnesty program seek extension to disclose
…US taxpayers that have unreported foreign assets to participate in the IRS Off-shore Voluntary Disclosure Program (OVDP) or seek to correct tax noncompliance through other avenues. The OVDP offers an…
New Extended Deadline for OVDI
Last week, late on Friday afternoon, August 26, 2011, the IRS issued a statement indicating that the due date for filing 2011 Offshore Voluntary Disclosure Initiative (OVDI) requests has been…
Numerous Criminal Prosecutions of Taxpayers with Unreported Offshore Accounts
…successful prosecutions underscore the government’s aggressive investigations and enhanced scrutiny. U.S. taxpayers who have failed to report their interests in offshore accounts should consider voluntary disclosures and the pending IRS…
US DOJ Tax Asst Attorney General Keneally Reports that One third of Swiss Banks Joining US DOJ Swiss Bank Program
…Swiss bank account should strongly consider disclosing that account now through the IRS Offshore Voluntary Disclosure Program (OVDP). The OVDP is a voluntary compliance initiative whereby individuals can receive amnesty…
Another Bank Discloses Accountholders: Credit Suisse to Turn Over U.S. Account Data
…to file a traditional voluntary disclosure via the IRS VDP program that would allow them to avoid potential criminal prosecution. In February 2009, UBS AG, the biggest Swiss bank, avoided…
New IRS Form 8938 Statement of Foreign Financial Assets is causing significant confusion
…be reported on Form 8938 that are not required to be reported on Form 90-22.1. Form 8938 May Force Taxpayers to Enter the Offshore Voluntary Disclosure Program (OVDP) This ability…
Fifth HSBC India Customer indicted for tax evasion this year
…for U.S. taxpayers with undisclosed HSBC accounts to take advantage of the IRS Voluntary Disclosure Program for offshore accounts. The IRS says there are 9,000 high net worth Indian US…