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
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
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 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
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
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
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
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
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
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
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 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
