opt out – Page 2 – Tax, Estate Planning & Probate Law Center

Benefits and consequences of entering or failing to enter the Offshore Voluntary Disclosure Initiative program

29 Nov 12

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 have succinctly summarized some of

Top 10 factors to consider before deciding to opt out of OVDI or OVDP

09 Oct 12

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 tax professionals should discuss the

2 recent IRS developments that will impact Indian Americans

16 Sep 12

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 Service (IRS) has been focusing heavily

New EZPASS OVDP Without Any Penalties for Non-Resident U.S. Taxpayers

02 Sep 12

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 delinquent FBARs for the past

Instructions for New Streamlined Filing Compliance Procedures for Non-Resident, Non-Filer U.S. Taxpayers

01 Sep 12

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 for the past six years.

The “Quiet” or “Silent” Disclosure

21 Aug 12

Our office consults with many clients in determining whether they need to enter into the 2012 IRS Offshore Voluntary Disclosure Program. Because of the high 27.5% penalty in the 2012 OVDP program, many of our clients are considering alternative options

To Opt Out or Not Opt Out: That is the Question

13 Aug 12

When is it appropriate to make a quiet disclosure vs. making a disclosure through the Offshore Voluntary Disclosure Program? This question is not necessarily easy to answer. IRS agents handling OVDI/OVDP cases do not have discretion regarding offshore-related information return

Explore the OVDI opt-out option: Argue for Penalty Mitigation

08 Aug 12

The revised IRS OVDP FAQs offer helpful guidance on the opt-out option. The newly revised FAQs illustrate the pros and cons of opting out with six examples. See FAQ 51. The examples describe situations in which it may be smart

Opting Out of the OVDI Program: Argue for No Penalty and a Warning Letter

27 Jul 12

The revised IRS OVDP FAQs offer helpful guidance on the opt-out option. The newly revised FAQs illustrate the pros and cons of opting out with examples. Depending on the circumstances, we sometimes recommend some clients to opt out of the

Full Analysis of Updated 2012 OVDP Program

15 Jul 12

The Internal Revenue Service announced on June 26, 2012 (IR-2012-64) that it is tightening eligibility requirements for the open-ended offshore voluntary disclosure program (2012 OVDP) that it announced in January 2012 for taxpayers with unreported income or assets, generally in

Should I close my foreign account?

23 Apr 12

Suppose you have a foreign bank account holding more than $10,000. You may have inherited it, used it to hide money during a dispute with your spouse or business partner, or just done it on a whim. As you try

IRS attempts to demystify its new Form 8938

08 Apr 12

The IRS has finally attempted to demystify its new Form 8938. Below are some Form 8938 FAQs: Basic Questions and Answers on Form 8938 1. What are the specified foreign financial assets that I need to report

More Tax Complexity: New Form 8938

07 Apr 12

In recent years, the IRS and US Treasury have stepped up their efforts toward tracking down delinquent tax payers and enforcing payment of overdue taxes. One of these initiatives has been labeled the “Foreign Account Tax Compliance Act”. FATCA is

Frequent Scenarios in Offshore Voluntary Disclosures

03 Apr 12

I have frequently seen the following scenarios in working with clients to determine whether a offshore voluntary disclosure program filing (OVDP) is appropriate and how they should report foreign account. First, a parent or grandparent entrusts a younger generation family

Analysis of the new 2012 Offshore Voluntary Disclosure Program (OVDP)

10 Jan 12

Yesterday the Internal Revenue Service opened its Offshore Voluntary Disclosure Program (OVDP) to encourage more taxpayers with assets in undeclared foreign bank accounts to come forward. While the OVDP was not expected by most tax lawyers and professionals, it may

IRS Announces New 2012 Offshore Voluntary Disclosure Program (OVDP)

09 Jan 12

The Internal Revenue Service today reopened the offshore voluntary disclosure program to help people hiding offshore accounts get current with their taxes. The IRS reopened the Offshore Voluntary Disclosure Program (OVDP) following continued strong interest from taxpayers and tax practitioners

The Risks of “Opting Out” of OVDI

29 Oct 11

Under the 2011 OVDI voluntary disclosure program, the penalties for failing to timely file Foreign Bank Account Reports, (FBAR’s) and the penalties for failure to file information returns (such as Controlled Foreign Corporation tax returns) were combined into a single

“Willfulness” When Deciding Whether to Opt Out of 2011 OVDI

11 Jul 11

The IRS recently posted guidance in its OVDI FAQs (#51) whether taxpayers should opt out of the 2011 Voluntary Disclosure Initiative’s (the “OVDI”) civil penalty structure. Taxpayers who participate in the OVDI, but feel that their failure to file the FBAR

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