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
A doctor has been convicted of failing to disclose to US federal authorities that he maintained offshore HSBC bank accounts in India and France and hid approximately $8 million in secret foreign bank accounts. Dr.
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
The IRS has recently published a useful chart outlining options available to help US taxpayers with offshore interests. The new IRS chart correctly states that it “recognizes that its focus on offshore enforcement efforts and
