The 2012 National Taxpayer Advocate (NTA) Annual Report to Congress criticized current IRS practices in the Offshore Voluntary Disclosure Program (OVDP) that hinder voluntary compliance by penalizing taxpayers who are entitled to a reasonable cause
Last month, HSBC Holdings agreed to pay $1.92 billion in fines to U.S. authorities, which is the largest collective settlement in the Treasury Department’s history. The penalty assessment was based upon HSBC’s conduct in violation
Bank Leumi is urging its U.S. clients to disclose information about their accounts to U.S. authorities investigating Leumi and many other foreign banks over possible tax avoidance by Americans. In a December 16 letter Leumi
I just returned from the American Bar Association Section of Taxation’s annual National Institute on Criminal Tax Fraud in Las Vegas. A topic of discussion was the relatively new New Streamlined Filing Compliance Procedures for
Over the past several years our law firm has counseled hundreds of non-compliant U.S. taxpayers in the exploration of their legal options with respect to the Offshore Voluntary Disclosure Initiative programs. As a result, we
The Department of Justice continues to prosecute cases involving United States taxpayers who have failed to report their interests in offshore accounts. Most of the cases are for large offshore accounts, but they provide good guidance
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 the 2009 OVDP, the IRS
While opting out of the OVDI or OVDP amnesty programs may result in a reduction of penalties that may otherwise be assessed, the taxpayer needs to carefully weigh the numerous consequences before doing so. Responsible
FATCA was enacted in 2010 by Congress to target non-compliance by U.S. taxpayers using foreign accounts. FATCA requires foreign financial institutions (FFIs) to report to the IRS information about financial accounts held by U.S. taxpayers,
Our firm was quoted last week in the Times of India newspaper: 2 recent IRS developments that will impact Indian Americans Deepa Venkatraghvan Sep 10, 2012, 07.54PM IST In the last few years, the US Internal Revenue
Yesterday, as expected, the IRS announced its new New Filing Compliance Procedures for Non-Resident U.S. Taxpayers that taxpayers presenting “low compliance risk” should file delinquent tax returns, including delinquent information returns, for the past three years; and
The IRS has announced its new New Filing Compliance Procedures for Non-Resident U.S. Taxpayers that taxpayers presenting “low compliance risk” should file delinquent tax returns, including delinquent information returns, for the past three years; and delinquent FBARs
