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Tag: voluntary disclosure

IRS collects over $5 billion in its its offshore voluntary disclosure programs

21 July, 2012

The Internal Revenue Service (IRS) has announced that its offshore voluntary disclosure programs (OVDPs) have collected more than $5 billion, and that it has tightened the eligibility requirements of the third program it opened in

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Full Analysis of Updated 2012 OVDP Program

15 July, 2012

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

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IRS offers tax opportunity to Americans living abroad

11 July, 2012

Many Americans (including US citizens and US green card holders) living abroad will get a small reprieve from U.S. Internal Revenue Service rules on reporting foreign assets, the agency announced on Tuesday. The IRS said

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OVDP Ineligibility Possibility Increases

27 June, 2012

Yesterday the IRS stated that taxpayers’ eligibility to participate in the OVDP could be terminated if the foreign institution where you have your account faces IRS action. Once the U.S. government has taken action against

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IRS Announces Penalty Mitigation for Smaller US Taxpayers Living Abroad

27 June, 2012

The Internal Revenue Service appears to have finally created a process to finally separate small non-resident (foreign resident) US taxpayers from larger non-resident US taxpayers at the front end, and not force everyone through the

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OVDI: Requesting issuance of a FBAR warning letter instead of penalties

29 May, 2012

In a Tax Notes Today report of statements made at the Eastern Pennsylvania Working Together Conference in Malvern, PA, Jason Kuratnick, IRS Associate Area Counsel (Philadelphia), Small Business / Self-Employed Division is reported to have

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Opting-out of the Offshore Voluntary Disclosure Initiative: FBAR Penalty Mitigation Guidelines

19 May, 2012

Depending on the circumstances, we sometimes recommend some taxpayers to opt out of the voluntary disclosure initiative and allow us to demonstrate the absence of willfulness and avoid the normal FBAR penalty regime. We have

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The legal standard of “willfulness”: Opt out to avoid high penalties

1 May, 2012

Under IRS Form 1040, at the bottom of Schedule B, Part III, on Page 2, Question 7(a) states: “at any time during the previous year, did you have any interest in or signatory or other

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Should I close my foreign account?

23 April, 2012

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

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Global Enforcement of FATCA: Something to Worry About

14 April, 2012

The Foreign Account Tax Compliance Act (FATCA) is about disclosure and transparency, but in part is to catch Americans trying to stash money overseas. Controversially, FATCA orders every foreign bank to track down its U.S.

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Difference between Form 8938 and FBAR Requirements

9 April, 2012

Comparison of Form 8938 and FBAR Requirements     Many holders of foreign financial assets must file two disclosure forms this year or else risk draconian penalties. They are Form 8938, which is due with

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Checklist of tax forms for taxpayers with foreign assets

9 April, 2012

This year, there is at least one new tax form for US taxpayers to be aware of: Form 8938: Statement of Foreign Financial Accounts. Since there are a number of sometimes obscure U.S. tax forms

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