Tag Archives: OVDP
New Warnings in the IRS’ Streamlined Filing Compliance Procedures
The Internal Revenue Service has recently updated the certification forms required to be filed by taxpayers seeking to avail themselves of the Streamlined Filing Compliance Procedures. The streamlined program was significantly expanded by the IRS in June 2014 in order
Large Penalties: Form 5471 Information Return of U.S. Persons With Respect to Certain Foreign Corporations
Internal Revenue Code (I.R.C.) Section (§) 6038(a) and Treasury Regulation § 1.6038-2(a) require a U.S. citizen or resident alien to furnish information with respect to certain foreign business entities. This information includes any foreign partnership/corporation entity data, stock ownership data,
IRS Announces New Clarifying FAQs for Streamlined Offshore Compliance Program
The IRS updated its streamlined offshore compliance program to provide procedures taxpayers residing both inside and outside the United States should use to participate in the program. The streamlined offshore compliance program is for taxpayers whose failure to comply with requirements to report
IRS Releases FAQs for the Delinquent International Information Return Submission Procedures
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 quote: The Delinquent International Information
IRS Streamlines its Streamlined Offshore Procedures with More User Friendly Forms
The IRS has just recently updated the Streamlined Procedure forms for both its “foreign” (SFOP) and “domestic” (SDOP) procedures. All of the information can now be typed directly into the fields. The statement of facts can be cut and pasted
IRS Official Provides Insights for the new IRS Streamlined Compliance Procedures
Taxpayers who are in the Offshore Voluntary Disclosure Program to report their overseas assets can request the favorable penalty structure under newly expanded streamlined compliance procedures without giving up the audit and criminal liability protection offered by the OVDP, according
Taxpayer’s Beware: Proving Non-Willful Conduct in the new IRS Streamlined Filing Compliance Procedures
Taxpayers should think carefully before entering a new Internal Revenue Service program titled Streamlined Filing Compliance Procedures for offshore-account holders whose conduct was not “willful”. On June 18th, the IRS announced significant changes to its limited-amnesty programs for U.S. taxpayers
New IRS Disclosure Program Announced for Non-Resident Taxpayers: Streamlined Foreign Offshore Procedures
The United States’ IRS is moving to entice more taxpayers to disclose their unreported assets and income just weeks before implementation of the U.S. Foreign Account Tax Compliance Act (FATCA). The IRS has announced a Streamlined Foreign Offshore Procedures (SFOP),
Swiss Banks’ Deadline to Disclose Information is Extended
The U.S. Department of Justice last Thursday issued a release stating that it extended for one month the deadline for so-called category two Swiss banks suspected of helping wealthy Americans evade taxes to turn over information by one month. We
Most Swiss banks participating in the US Department of Justice (DOJ) amnesty program seek extension to disclose
By April 30, 2014, unless granted a 60-day extension, all Swiss banks participating in the US Department of Justice (DOJ) amnesty program will be required to provide substantial client information on its US account holders. We have previously posted on
Canada and US sign FATCA tax deal where banks to share information with IRS
Ottawa and Washington have reached a compromise over how to apply a U.S. law targeting would-be American tax dodgers living in Canada. Canada has signed an agreement with the U.S. on the automatic sharing of bank information between the two
US DOJ Tax Asst Attorney General Keneally Reports that One third of Swiss Banks Joining US DOJ Swiss Bank Program
We have previously posted on the U.S. Justice Department’s program offered to Swiss banks and targeted to identifying U.S. taxpayers that have not disclosed foreign accounts to the IRS. It has now been stated that that one-third of all Swiss