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What Is The Difference Between the SDOP and the Current OVDP program?: Willfulness

3 October, 2014

What Is The Difference Between the SDOP and the Current OVDP program? The Streamlined Offshore Procedures (SDOP and SFOP) liberalizes the old restrictions and rewards taxpayers that disclose their offshore assets with a lower penalty

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New IRS internal procedure guidance for Streamline Filing Compliance Procedures

3 September, 2014

The IRS has published new IRS internal procedure guidance with IRM changes dated 8/13/14.  The guidance is numbered WI-21-0814-1244 and titled “Streamline Filing Compliance Procedures for Accounts Management International IMF”.  The guidance is here. The general

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50% Penalty for Taxpayers Who Hold Accounts at a Bank Under Investigation

21 June, 2014

The Internal Revenue Service announced last week changes to its programs for taxpayers with undeclared offshore accounts, the latest step in a five-year campaign against such accounts held by U.S. taxpayers. The modifications greatly eased penalties

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Swiss Bank Disclosure Round Up

2 January, 2014

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 coming weeks, as Switzerland’s cherished bank

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More Swiss Banks Agree to Cooperate with the IRS

31 December, 2013

Lombard Odier & Cie and VP Bank (Switzerland) last week became the latest Swiss banks to say they would work with U.S. officials in a crackdown on lenders suspected of helping wealthy Americans evade taxes

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Argue for No Penalty and a Warning Letter for FBAR Violations

22 December, 2013

The IRS may send a warning letter in lieu of asserting penalties for failure to file a Form TD F 90-22.1, “Report of Foreign Bank and Financial Accounts,” if it would be sufficient to bring

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Swiss Banks are Pressuring Customers to Disclose

21 December, 2013

Swiss banks are pressuring current and former U.S. account holders to disclose undeclared assets to the Internal Revenue Service. In some cases, the banks are freezing accounts unless clients can prove they have declared the

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US Department of Justice Encourages Swiss banks to Disclose Information

15 December, 2013

Last week the Tax Division of the Department of Justice strongly encouraged Swiss banks that want to seek non-prosecution agreements to resolve past cross-border criminal tax violations to submit letters of intent by the Dec.

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More Swiss Banks Agree to Disclose US Customers Accounts: Expect More Customer Letters to be Sent

12 December, 2013

As of yesterday, three Swiss banks have agreed to participate in a U.S. disclosure program aimed at lenders suspected of aiding tax evasion by Americans.  Many more expected and thousands of letters are being sent

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New FinCEN Form 114 (FBAR) Filing Rules Announced

29 September, 2013

Responding to the needs of many filers who submit Reports of Foreign Bank and Financial Accounts (FBARs) jointly with spouses, or wish to submit them via third-party preparers, the Financial Crimes Enforcement Network (FinCEN) today

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Foreign Account Tax Compliance Act (FATCA) online registration program is launched

26 August, 2013

The Internal Revenue Service on Monday launched an online registration program for the hundreds of thousands of financial firms around the world that must comply with a U.S. anti-tax evasion law or risk being shut

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Finally: IRS Reminds Those with Foreign Assets of U.S. Tax Obligations

29 May, 2013

The IRS has finally decided that educating taxpayers and tax advisors of tax obligations of foreign assets and income would be helpful and encourage compliance. The recent education announcements appear to address the IRS’ alleged

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