voluntary disclosure – Page 3 – Tax, Estate Planning & Probate Law Center

New IRS Subpoenae and IRS Data Mining Expected

26 Dec 14

Last week a federal judge approved the IRS issuing “John Doe” summonses requiring FedEx, DHL, UPS, and numerous other intermediaries to produce information about U.S. taxpayers who used Sovereign Management & Legal Ltd. for offshore accounts and assets. They include

News from the 2014 Criminal Fraud and Tax Controversy Conference

22 Dec 14

We just returned last week from attending the Criminal Fraud and Tax Controversy Conference in Las Vegas, sponsored by the American Bar Association Section of Taxation where many government officials were in attendance. Below are some interesting observations: On the

IRS Releases Training Documents on Offshore Voluntary Disclosure Program

02 Dec 14

last month the IRS released more than 6,500 pages from the Internal Revenue Service on the agency’s Offshore Voluntary Disclosure Program and how it trains its agents. The documents included material used in training IRS personnel in the Offshore Voluntary Disclosure Program,

IRS Announces New Clarifying FAQs for Streamlined Offshore Compliance Program

25 Oct 14

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

19 Oct 14

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 Clarifies Requirements for Streamlined Filing Procedures

15 Oct 14

Our office has received many inquiries from taxpayers interested in the Streamlined Filing Compliance Procedures with the new lower penalty. However IRS guidance and instructions was unclear and ambiguous in certain areas. Last week, on October 9, 2014, the Internal

OVDP New Forms Announced by IRS

10 Oct 14

The IRS has simplified the process of entering the OVDP Program by issuing the following forms: Form 14457 – Offshore Voluntary Disclosure Letter Form 14454 – Offshore Voluntary Disclosure Program Letter Attachment The new forms (the old forms were simple Word documents)

What Is The Difference Between the SDOP and the Current OVDP program?: Willfulness

03 Oct 14

What Is The Difference Between the SDOP and the Current OVDP program? The Streamlined Offshore Procedures (SDOP and SFOP) liberalizes the old restrictions and rewards taxpayers that disclose their offshore assets with a lower penalty and a very low tax.

IRS Streamlines its Streamlined Offshore Procedures with More User Friendly Forms

01 Oct 14

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

Watch Out for Letters From Your Foreign Bank Requesting Information On Your U.S. Residency

17 Sep 14

Numerous foreign banks are sending letters to their customers demanding personal information to ascertain whether the customer is a U.S. citizen or a U.S. resident. The foreign banks typically state they are required to obtain such personal information pursuant to the U.S. Foreign Account

Citizenship renunciation fee increases as American expatriates flee FATCA

13 Sep 14

US government fees charged to Americans for renouncing their citizenship will rocket from $450 to $2,350 on September 12, 2014. The fivefold increase is probably related to the recent dramatic rise in renunciations triggered by the US Foreign Account Tax Compliance

New IRS internal procedure guidance for Streamline Filing Compliance Procedures

03 Sep 14

The IRS has published new IRS internal procedure guidance with IRM changes dated 8/13/14. The guidance is numbered WI-21-0814-1244 and titled “Streamline Filing Compliance Procedures for Accounts Management International IMF”. The guidance is here. The general legal rule is that IRM

IRS Official Provides Insights for the new IRS Streamlined Compliance Procedures

15 Aug 14

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

How to Demonstrate Non-Willfulness Under The Streamlined Filing Compliance Procedures

11 Aug 14

The IRS recently announced Streamlined Filing Compliance Procedures in an effort to encourage U.S. taxpayers to come into compliance with their reporting and filing requirements associated with varying interests in foreign financial accounts and assets. The streamlined procedures require the

Taxpayer’s Beware: Proving Non-Willful Conduct in the new IRS Streamlined Filing Compliance Procedures

02 Jul 14

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

IRS announces new Streamlined Filing Compliance Procedures

30 Jun 14

The IRS announced substantial changes to both the Streamlined Filing Compliance Procedures for Non-Resident, Non-Filer Taxpayers and the Offshore Voluntary Disclosure Program (OVDP) on June 18, 2014. Effective July 1, 2014, the IRS is making it easier for individuals to

50% Penalty for Taxpayers Who Hold Accounts at a Bank Under Investigation

21 Jun 14

The Internal Revenue Service announced last week changes to its programs for taxpayers with undeclared offshore accounts, the latest step in a five-year campaign against such accounts held by U.S. taxpayers. The modifications greatly eased penalties for people who were unaware

New IRS Disclosure Program Announced for Non-Resident Taxpayers: Streamlined Foreign Offshore Procedures

21 Jun 14

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),

IRS Announces Major New changes to the Offshore Voluntary Disclosure Program

18 Jun 14

The IRS today made significant changes to its offshore voluntary compliance programs, with the intent of providing new options to help both taxpayers residing overseas and those residing in the United States. The agency says the changes are anticipated to provide

New Streamlined Domestic Offshore Procedures (SDOP) is a Game Changer

18 Jun 14

The IRS has announced a Streamlined Domestic Offshore Procedures (SDOP), which will significantly alter all future voluntary disclosures. The SDOP is a game changer for residents and non-resident (who would use the Streamlined Foreign Offshore Procedures (SFOP)) taxpayers alike. The

FBAR Reporting Season is here

16 Jun 14

All taxpayers are reminded about FBAR reporting this year, as the process has changed. If you have a financial interest in or signature authority over a foreign financial account, including a bank account, brokerage account, mutual fund, trust, or other

New offshore voluntary disclosure program (OVDP) changes expected to be favorable to taxpayers

09 Jun 14

During Internal Revenue Service (IRS) Commissioner John Koskinen’s remarks at a speech before the United States Council-OECD International Tax Conference in Washington last week, he indicated that the agency is preparing a new offshore voluntary disclosure program (OVDP) that will

Swiss Banks’ Deadline to Disclose Information is Extended

09 Jun 14

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

FATCA-Compliant Institutions List Goes Online

03 Jun 14

While over 77,000 banks and financial institutions have registered under FATCA—the Foreign Account Tax Compliance Act, the Internal Revenue Service has introduced an online tool that will allow users to check on whether a foreign financial institution has registered for

US Government Continues to Pressure Swiss Banks

15 May 14

The US government is putting pressure on Switzerland to end its tradition of “banking secrecy”, as part of a global crackdown on tax evasion. Since forcing UBS to pay a USD780 million fine in 2009 for helping US citizens evade

India Signs FATCA Model Intergovernmental Agreement to Share Account Information with the US

02 May 14

The U.S. Treasury announced that on April 11, 2014, India agreed “in substance” to sign a Model 1 FATCA Model Intergovernmental Agreement (IGA) with the US. The IGA would therefore require Indian financial institutions to report information on U.S. account holders to

IRS Reminds (again) Taxpayers to Report Foreign Income and Assets

30 Apr 14

Earlier this month on April 11, 2014, the Internal Revenue Service issued Notice IR-2014-52 reminding U.S. citizens and resident aliens, including those with dual citizenship who have lived or worked abroad during all or part of 2013, that they may have a

Most Swiss banks participating in the US Department of Justice (DOJ) amnesty program seek extension to disclose

28 Apr 14

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

Cayman Islands Advisors Arrest Suggest U.S. Government Receiving More Information About Offshore Accounts

08 Apr 14

According to a DOJ Tax Press Release, here, the IRS has arrested a U.S. Citizen and two Canadian citizens who offered enabler services to U.S. taxpayers. They were caught in a classic IRS sting operation. Here is a summary of the

Republican Party Rallies Against FATCA: Success Unlikely

22 Feb 14

The Republican Party is expected to approve a resolution calling for repeal of an Obama administration law that is designed to crack down on offshore tax dodging. In what would be the party’s first appeal to scrap the law -the

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