Search Results for: voluntary disclosure programs
Top FBAR Reporting Error
…programs, many U.S. persons with foreign financial accounts remain unaware of the FBAR reporting obligations. U.S. persons with ownership or signature authority over foreign financial accounts should obtain complete copies…
Taxpayers’ Evidence of Non-Willfulness or Willfulness Factors
…is really non-willful. Unfortunately, the IRS has publicly stated that it will intentionally give no further definition of non-willful conduct for purposes of the Streamline Compliance Programs (SFOP or the…
New Taxpayer Advocate Service Report Discusses Optouts out of the OVDI/OVDP
…The IRS has also started to establish exclusive “optout” offices, which probably means that more optouts are expected. Regardless, while opting out of the OVDI or OVDP amnesty programs may…
Living Wills in New Jersey
…Directive exists, a copy must be attached to the patient’s medial records. Health care institutions including hospitals, nursing homes, home health care agencies and hospice programs are required to adopt…
Beware IRS Letter 6291
…can still become compliant by entering one of the IRS amnesty programs and making payment for applicable taxes, interest, and penalties. HOW TO RESPOND: If you received IRS Letter 6291,…
New IRS Relief for Taxpayers Experiencing COVID-related Difficulties
…abatement programs in the IRS. · For individual taxpayers receiving notices (letters about a tax bill) with tax liabilities up to $250,000 for Tax Year 2019 only, the IRS can…
The Need for Long Term Care Planning
…done by purchasing long-term care insurance or by making sure you receive the benefits to which you are entitled under the Medicare and Medicaid programs. Veterans may also seek benefits…
FATCA Enforcement Softens
…and ultimately IRS examiners, will have to apply. Therefore, withholding agents should “continue the course” of their FATCA programs and modifications to existing procedures required by the conforming regulations, while…
Foreign pension accounts reporting on the FBAR
…countries have some form of Provident Fund which is geared toward retirement. Despite the similarities with social security-type programs, these types of foreign pension plans must be reported on FBAR….
Is the IRS Finally Receiving Increased Funding?
…revenue laws and other financial crimes; purchase and hire passenger motor vehicles; and provide other services. Operations Support: $25,326,400,000 Support taxpayer services and enforcement programs, including rent payments; facilities services;…
Pandora’s Box Has Opened: Pandora Papers
…defeat any tax can be criminally prosecuted. The IRS has special programs for taxpayers to come forward to disclose unreported foreign accounts and unreported foreign income. Affected persons should not…
Delinquent FinCen Form 114 (FBAR) Filings
…filings have caused confusion over the various IRS programs in place for individuals who need to become compliant with FBARs. Due to the risk of audit and high penalties, we…
Conservatorship or Legal Guardianship: Which is the Right Choice?
In New Jersey, a conservatorship is generally more limited than a legal guardianship and is a voluntary step taken by the ward. Like a legal guardianship, a conservatorship is a…
New Form 3520 Penalties
…assessment of penalties. Since the streamlined filing compliance procedures are already in place, this solution would be relatively easy to implement. This would also encourage voluntary compliance with Form 3520….
What Is The Difference Between the SDOP and the Current OVDP program?: Willfulness
…assets with a lower penalty and a very low tax. Taxpayers will only have to file 3 years of amended income tax returns instead of the current OVDP program’s requirement…
Willful FBAR Penalties
…is evidence that filing the FBAR late or not at all was voluntary and intentional. Evidence must be shown by the government of the taxpayer knowing a reporting requirement exists…
How to Avoid Employee Retention Credit (ERC) Scams
…to employer customers), which do not qualify under Notice 2021-20. A voluntary shutdown of an employer that was not required to close due to a governmental order. Many “critical infrastructure”…
New Streamlined Domestic Offshore Procedures (SDOP) is a Game Changer
The IRS has announced a Streamlined Domestic Offshore Procedures (SDOP), which will significantly alter all future voluntary disclosures. The SDOP is a game changer for residents and non-resident (who would…
HSBC Bank Expects Significant Penalties from US Government for Violations
…whether certain HSBC companies and employees acted appropriately in relation to certain customers with US tax reporting requirements. The disclosure was made by UK-based HSBC as part of an update…
Foreign mutual funds = Passive Foreign Investment Companies (PFICs)?
…their shareholders. These amounts are then reported annually to the IRS on a Form 1099. Foreign investment companies are not subject to U.S. taxes or to these disclosure rules. As…
HSBC Customer Avoids Jail in Tax Evasion Case
…including increased criminal prosecutions and civil audit examinations. We have been advising our clients to expect the unexpected (and the worst) in their tax treatment and disclosure of offshore assets….
The IRS can revoke your passport
…passport certification and decertification notices to be sent to representatives where such disclosure is authorized under the law. Our new website IRSRevokedPassport.com provides numerous solutions to clients with passport problems…
IRS Summons to a Third Party: Duties and Rights
…summonsed witness may also request to have a non-attorney witness present at the production of documents and records, but he or she must first sign a non-disclosure waiver. Moreover, anyone…
India and the US have agreed to collaborate on offshore tax evasion
…their tax treatment and disclosure of offshore assets, particularly for Indian assets. Patel Law Offices has consulted with hundreds of clients regarding their offshore asset compliance issues. Patel Law Offices…
IRS Official Announces New Focus on Offshore Assets in Indian Banks
…tax treatment and disclosure of offshore assets, particularly for Indian assets. Patel Law Offices has consulted with hundreds of clients regarding their offshore asset compliance issues. Patel Law Offices is…
Trinidad and Tobago and the United States sign new agreement to exchange of information under FATCA
…unexpected (and the worst) in their tax treatment and disclosure of offshore assets. Patel Law Offices has consulted with hundreds of clients regarding their offshore asset compliance issues. Patel Law…
Malta Pension Plan Being Investigated by IRS Criminal Investigation Division
…arrangements will be subject to the same additional scrutiny applicable to all listed transactions, including certain disclosure requirements, increased penalty exposure, and record-keeping requirements for material advisors. In a significant…
Watch Out: Malta Pension Plans Become Listed Transaction
…scheme as a “listed transaction.” A listed transaction is a tax avoidance scheme that has been identified by the IRS. Participants in listed transactions must file a disclosure statement with…
Argue for No Penalty and a Warning Letter for FBAR Violations
…criminal prosecutions and civil audit examinations. We have been advising our clients to expect the unexpected (and the worst) in their tax treatment and disclosure of offshore assets. Patel Law…
An Ill-advised IRS Streamlined Filing Compliance Procedure Filing
…legal advice regarding which disclosure program to pursue. Mr. Gyetvay’s SFCP filing was too large and complex and had willful factors. He should not have filed in the Streamline program….