penalties and interest – Page 5 – Tax, Estate Planning & Probate Law Center

IRS Form 8938 and the Offshore Voluntary Disclosure Program (OVDP)

30 Jan 12

The announcement by the IRS of the opening of the new Offshore Voluntary Disclosure Program (OVDP) on January 9, 2012 came as a surprise to most tax practitioners, especially since the 2011 OVDI just ended on September 9, 2011. However,

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

Beware: IRS Form 8938 Statement of Specified Foreign Financial Assets

03 Jan 12

Form 8938, Statement of Specified Foreign Financial Assets, is a new reporting form. Form 8938 will be used to report certain foreign financial assets as required as part of the Hiring Incentives to Restore Employment Act (HIRE Act), which was

IRS Reminds U.S. citizens and dual citizens about U.S. filing requirements

12 Dec 11

In a fact sheet (IRS FS-2011-13) released last week, the IRS reminded U.S. citizens and dual citizens of the United States and foreign countries who live abroad about U.S. filing requirements, including Form TD F 90-22.1, Report of Foreign Bank

Another Bank Discloses Accountholders: Credit Suisse to Turn Over U.S. Account Data

28 Nov 11

Earlier this month Credit Suisse Group AG, Switzerland’s second-biggest bank, told U.S. clients it is giving confidential client account data to the Swiss tax authorities, who will decide whether to disclose it to the Internal Revenue Service. The U.S. is

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

What if You Missed the OVDI Deadline?

07 Oct 11

Although the OVDI program has expired, a U.S. taxpayer can still make a voluntary disclosure of foreign accounts pursuant to the IRS’s general voluntary disclosure policy. For over 50 years, the IRS has maintained a voluntary disclosure policy, under which

Employee or Contractor?: The IRS’s New Voluntary Classification Settlement Program (VCSP)

28 Sep 11

When the IRS says “voluntary” it can sound scary. The IRS is unlikely to use this word unless the potential liability is serious. The IRS would much rather have you come forward. If you do, you’re likely to get a

With No More Amnesty Program: Explore the IRS’s Traditional Voluntary Disclosure program

14 Sep 11

Even though the deadline for the Internal Revenue Service’s 2011 Offshore Voluntary Disclosure Initiative has concluded last week, U.S. taxpayers with undisclosed offshore accounts still have the opportunity to come forward through the IRS’s traditional Voluntary Disclosure program. Like the

Audit Beware: IRS’ Global High Wealth Industry Group

18 Aug 11

A recent article in the Wall Street Journal discussed the new IRS’ Global High Wealth Industry Group. Over 1 year ago we warned readers of the new group when Commissioner Shulman announced its formation in an address to the American

FATCAts

14 Aug 11

If the US dollar is as close as we have come to a global currency — accepted everywhere from Fifth Avenue boutiques to Coca-Cola stands in Afghanistan — why are some American citizens finding it hard to put their money

One Month Countdown: The Deadline is Nearing for U.S. Taxpayers with Undisclosed Accounts to Come Forward

01 Aug 11

The deadline to enter a complete submission into the 2011 Offshore Voluntary Disclosure Initiative (OVDI) is August 31, 2011, only one month remains and time is running out. The OVDI provides an opportunity for taxpayers with undisclosed offshore accounts to

Foreign Account Penalties Are Unfair

08 Jul 11

Our office is advising dozens of clients (including many HSBC customers) regarding offshore accounts, all of whom may be subject to large unfair penalties. Finally it appears that someone in government is realizing the unfairness of the offshore penalties. In

IRS Announces “Good Faith” 90 Day Extension of Voluntary Disclosure Deadline

08 Jun 11

The IRS said last week that it is making available to taxpayers a 90-day deadline extension to participate in the 2011 offshore voluntary disclosure initiative (OVDI). The extension would be available to taxpayers who have made a good faith attempt

Numerous Criminal Prosecutions of Taxpayers with Unreported Offshore Accounts

01 Jun 11

The Department of Justice and local United States Attorneys’ Offices continue to zealously prosecute numerous cases involving U.S. taxpayers who have failed to report their interests in offshore accounts. The successful prosecutions underscore the government’s aggressive investigations and enhanced scrutiny.

HSBC and NRI Bank Accounts: Could It Spread to Other Banks?

16 May 11

The US Internal Revenue Service (IRS) has asked HSBC Bank to provide information on incomes of US residents who may be using accounts in India to evade income taxes. The move has raised several questions. First, why did US authorities

Time Running Out for HSBC India accountholders sought by IRS

28 Apr 11

If HSBC produces these records, which is likely, it may be too late for U.S. taxpayers with undisclosed HSBC accounts to take advantage of the IRS Voluntary Disclosure Program for offshore accounts.

HSBC Expected to Disclose Account Holders Names

19 Apr 11

The IRS has petitioned for a federal court authorization to enable it to obtain information on HSBC Bank’s American account holders using their foreign accounts to evade taxes. Most of these account holders are believed to be Americans of Indian

Post IRS Audit Strategic Options: The IRS’ 30 Day Letter

09 Apr 11

If, after conducting the audit, a taxpayer and revenue agent cannot come to an agreement, the agent will prepare and submit to the taxpayer a preliminary notice of deficiency, or “30-day letter.” The 30-day letter is a form letter that sets

Financial Crimes Enforcement Network (FINCEN) Issue Final Rules

21 Mar 11

The Bank Secrecy Act (“BSA”) was originally enacted in 1970 to help detect and prevent money laundering. The BSA requires reporting for a calendar year called a “Report of Foreign Bank and Financial Accounts” (Form TD F 90-22.1 (the “FBAR”)),

2011 Offshore Voluntary Disclosure Initiative (OVDI)

11 Feb 11

On February 8, 2011, the IRS announced the 2011 Offshore Voluntary Disclosure Initiative (OVDI), designed to bring offshore money back into the U.S. tax system and help people with undisclosed income from hidden offshore accounts get current with their taxes.

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