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U.S. Taxpayers at New Risk of Audit from OVDP Declines and Withdrawals Campaign

19 June, 2017

Last year, the US Treasury Inspector General for Tax Administration (TIGTA) released a report which assessed how well that IRS was managing the Offshore Voluntary Disclosure Program (OVDP). OVDP is one of the programs taxpayers

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Streamlined Filing Compliance Procedure’s New Revisions to Streamlined Domestic Offshore Procedures (SDOP)

28 March, 2016

In the midst of tough tax season, many U.S taxpayers are unfortunately surprised to discover that they have a U.S. tax reporting obligation on financial accounts or assets held overseas. Once they discover their tax

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File a Protective Claim for Refund for Possible OVDP Opt Out Cases

3 October, 2015

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 issues exist in connection with

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The Tax Issues of Expatriation

26 May, 2015

The “United States Permanent Resident Card”, also known as a Green Card, as a work and residence permit for the USA of unlimited duration and as an immigration visa, constitutes an admission ticket to the

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Helpful Non-willful FBAR penalty case decided by court

6 May, 2015

For the first time, in the case of James Moore, Plaintiff v. United States of America, Defendant (James Moore v. U.S. Case 2:13-cv-02063-RAJ filed 4/1/15), we finally get a look at some non-willful FBAR penalty

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National Taxpayer Advocate Delivers Annual Report to Congress that Criticizes Offshore Voluntary Disclosure Programs

14 January, 2015

National Taxpayer Advocate Nina E. Olson today released her 2014 annual report to Congress, which expresses concern that taxpayers this year are likely to receive the worst levels of taxpayer service since at least 2001

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New IRS Subpoenae and IRS Data Mining Expected

26 December, 2014

Last week a federal judge approved the IRS issuing “John Doe” summonses requiring FedEx, DHL, UPS, and numerous other intermediaries to produce information about U.S. taxpayers who used Sovereign Management & Legal Ltd. for offshore

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IRS Releases FAQs for the Delinquent International Information Return Submission Procedures

19 October, 2014

The IRS recently released frequently asked questions for the Delinquent International Information Return Submission Procedures (available here). The IRS now states that these procedures are available to taxpayers even if they have unreported income. See below

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New Report: Delinquent Taxpayers Could be Identified at US Border Crossings

19 October, 2014

The Internal Revenue Service’s collection efforts need to be improved to make sure that delinquent taxpayers residing in foreign countries comply with their U.S. tax obligations, according to a new government report. The report, from the

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OVDP New Forms Announced by IRS

10 October, 2014

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 Letter Attachment The new forms (the old

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FBAR Reporting Season is here

16 June, 2014

All taxpayers are reminded about FBAR reporting this year, as the process has changed. If you have a financial interest in or signature authority over a foreign financial account, including a bank account, brokerage account,

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No More Delays for FATCA: Get Ready for Disclosure

13 February, 2014

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 Internal Revenue Service (IRS). FATCA,

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Recent Posts

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  • The High Price of Payroll Tax Non-Compliance: Lessons from United States v. PittsSeptember 15, 2026
  • FBAR Willfulness, Recklessness, and the Excessive Fines Defense: Key Takeaways from United States v. RundSeptember 11, 2026
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  • Billions Offshore, Millions Missed: What TIGTA’s Report Means for FATCA EnforcementSeptember 2, 2026
  • Criminal Tax Enforcement Takes Center Stage: The National Fraud Enforcement Division MemorandumAugust 21, 2026
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  • IRS Transitions from First Time Abatement to Automated Penalty Relief: Strategic Impacts for Tax AdvisorsJuly 11, 2026
  • Parag Patel to Present on IRS Foreign Asset Enforcement at the 2026 NATP TaxposiumJuly 9, 2026

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