Skip to content
Tax Law Center Blog

Tax Law Center Blog

  • Tax & Foreign Assets
    • Tax Law Services
    • Foreign Asset Planning
  • About
  • Contact Us
Close Button

Tag: voluntary disclosure

Argue for No Penalty and a Warning Letter for FBAR Violations

22 December, 2013

The IRS may send a warning letter in lieu of asserting penalties for failure to file a Form TD F 90-22.1, “Report of Foreign Bank and Financial Accounts,” if it would be sufficient to bring

Read More

Swiss Banks are Pressuring Customers to Disclose

21 December, 2013

Swiss banks are pressuring current and former U.S. account holders to disclose undeclared assets to the Internal Revenue Service. In some cases, the banks are freezing accounts unless clients can prove they have declared the

Read More

US Department of Justice Encourages Swiss banks to Disclose Information

15 December, 2013

Last week the Tax Division of the Department of Justice strongly encouraged Swiss banks that want to seek non-prosecution agreements to resolve past cross-border criminal tax violations to submit letters of intent by the Dec.

Read More

Method to Cure Delinquent or Incomplete Foreign Information Returns Without Penalties

14 December, 2013

Last year, the IRS announced its third offshore voluntary disclosure initiative. Like the earlier initiatives, the 2012 OVDP is designed to encourage taxpayers with unreported offshore accounts and assets to voluntarily disclose them to the

Read More

More Swiss Banks Agree to Disclose US Customers Accounts: Expect More Customer Letters to be Sent

12 December, 2013

As of yesterday, three Swiss banks have agreed to participate in a U.S. disclosure program aimed at lenders suspected of aiding tax evasion by Americans.  Many more expected and thousands of letters are being sent

Read More

Comparison of Form 8938 and FBAR Requirements

9 December, 2013

The new Form 8938 filing requirement does not replace or otherwise affect a taxpayer’s obligation to file FinCEN  Form 114 (Report of Foreign Bank and Financial Accounts). Individuals must file each form for which they

Read More

IRS Announces New Rules for FBAR Penalties

27 November, 2013

There are two types of penalties applicable to FinCEN  Form 114 (Report of Foreign Bank and Financial Accounts) (FBARs):  (1) Non-Willful and (2) Willful.  The penalties are theoretically assessed per account and not per FBAR;

Read More

IRS Official Announces New Focus on Offshore Assets in Indian Banks

20 November, 2013

Reporting on a California State Bar Tax Section Meeting, Tax Notes reports that the IRS will soon (as early as the week of 11/11/13) ) “begin examining U.S. taxpayers suspected of holding undeclared accounts in

Read More

New FinCEN Form 114 (FBAR) Filing Rules Announced

29 September, 2013

Responding to the needs of many filers who submit Reports of Foreign Bank and Financial Accounts (FBARs) jointly with spouses, or wish to submit them via third-party preparers, the Financial Crimes Enforcement Network (FinCEN) today

Read More

Swiss Government and US Government Announce New Program for Cooperation and Disclosure by Swiss Banks

12 September, 2013

In August 2013, the Swiss Federal Government and the DOJ announced a first of its kind program (the New Program) that will enable eligible Swiss banks to address and resolve their status with regard to the

Read More

Offshore Voluntary Disclosure Initiative/Program (OVDI/OVDP) opt-out results and updates

12 September, 2013

Many of our clients are carefully considering OVDI opt-outs. The opt out option became first available during the 2011 OVDI program, and continues with the current OVDP program. The 2012 OVDP program continues the procedures announced in

Read More

Foreign Account Tax Compliance Act (FATCA) online registration program is launched

26 August, 2013

The Internal Revenue Service on Monday launched an online registration program for the hundreds of thousands of financial firms around the world that must comply with a U.S. anti-tax evasion law or risk being shut

Read More

Posts pagination

Previous page Page 1 … Page 8 Page 9 Page 10 … Page 18 Next page

Recent Posts

  • The Enforcement Surge: What the DOJ and IRS Campaign Means for Tax Professionals and Their ClientsOctober 17, 2026
  • The High Price of Payroll Tax Non-Compliance: Lessons from United States v. PittsSeptember 15, 2026
  • FBAR Willfulness, Recklessness, and the Excessive Fines Defense: Key Takeaways from United States v. RundSeptember 11, 2026
  • FBAR Enforcement and Penalty Analysis: United States v. NiksichSeptember 5, 2026
  • Billions Offshore, Millions Missed: What TIGTA’s Report Means for FATCA EnforcementSeptember 2, 2026
  • Criminal Tax Enforcement Takes Center Stage: The National Fraud Enforcement Division MemorandumAugust 21, 2026
  • Navigating New Jersey Tobacco and Vapor Excise Tax AuditsAugust 11, 2026
  • Navigating the US Estate Portability Election: Strategic Timing and Compliance Procedures for Form 706July 13, 2026
  • IRS Transitions from First Time Abatement to Automated Penalty Relief: Strategic Impacts for Tax AdvisorsJuly 11, 2026
  • Parag Patel to Present on IRS Foreign Asset Enforcement at the 2026 NATP TaxposiumJuly 9, 2026

Search

Archives

  • October 2026
  • September 2026
  • August 2026
  • July 2026
  • June 2026
  • May 2026
  • April 2026
  • March 2026
  • February 2026
  • January 2026
  • November 2025
  • October 2025
  • September 2025
  • August 2025
  • July 2025
  • June 2025
  • May 2025
  • March 2025
  • February 2025
  • January 2025
  • December 2024
  • November 2024
  • October 2024
  • August 2024
  • July 2024
  • June 2024
  • May 2024
  • April 2024
  • March 2024
  • February 2024
  • January 2024
  • December 2023
  • November 2023
  • October 2023
  • August 2023
  • July 2023
  • June 2023
  • May 2023
  • April 2023
  • March 2023
  • February 2023
  • January 2023
  • December 2022
  • November 2022
  • October 2022
  • September 2022
  • August 2022
  • July 2022
  • June 2022
  • April 2022
  • March 2022
  • January 2022
  • December 2021
  • November 2021
  • October 2021
  • September 2021
  • August 2021
  • July 2021
  • June 2021
  • May 2021
  • April 2021
  • March 2021
  • February 2021
  • January 2021
  • December 2020
  • November 2020
  • October 2020
  • September 2020
  • August 2020
  • July 2020
  • June 2020
  • May 2020
  • April 2020
  • March 2020
  • February 2020
  • January 2020
  • December 2019
  • November 2019
  • September 2019
  • August 2019
  • July 2019
  • June 2019
  • May 2019
  • March 2019
  • February 2019
  • January 2019
  • December 2018
  • November 2018
  • September 2018
  • July 2018
  • June 2018
  • May 2018
  • April 2018
  • March 2018
  • February 2018
  • January 2018
  • December 2017
  • November 2017
  • October 2017
  • September 2017
  • August 2017
  • June 2017
  • May 2017
  • April 2017
  • March 2017
  • February 2017
  • January 2017
  • December 2016
  • November 2016
  • October 2016
  • September 2016
  • August 2016
  • July 2016
  • June 2016
  • April 2016
  • March 2016
  • February 2016
  • January 2016
  • December 2015
  • November 2015
  • October 2015
  • September 2015
  • August 2015
  • July 2015
  • June 2015
  • May 2015
  • April 2015
  • March 2015
  • January 2015
  • December 2014
  • November 2014
  • October 2014
  • September 2014
  • August 2014
  • July 2014
  • June 2014
  • May 2014
  • April 2014
  • February 2014
  • January 2014
  • December 2013
  • November 2013
  • October 2013
  • September 2013
  • August 2013
  • July 2013
  • June 2013
  • May 2013
  • April 2013
  • March 2013
  • February 2013
  • January 2013
  • December 2012
  • November 2012
  • October 2012
  • September 2012
  • August 2012
  • July 2012
  • June 2012
  • May 2012
  • April 2012
  • March 2012
  • February 2012
  • January 2012
  • December 2011
  • November 2011
  • October 2011
  • September 2011
  • August 2011
  • July 2011
  • June 2011
  • May 2011
  • April 2011
  • March 2011
  • February 2011
  • January 2011
  • December 2010
  • October 2010
  • September 2010
  • August 2010
  • June 2010
  • May 2010
  • April 2010
  • March 2010
  • February 2010
  • January 2010
  • December 2009
  • November 2009
  • October 2009
  • September 2009
  • August 2009
  • July 2009
  • May 2009
  • April 2009
  • March 2009
  • February 2009
  • January 2009
  • December 2008
  • November 2008
  • October 2008
  • September 2008
  • August 2008
  • July 2008
  • June 2008
  • May 2008
  • April 2008
  • March 2008
  • February 2008
  • January 2008
  • December 2007
  • November 2007
  • August 2007
  • July 2007
  • April 2007
  • March 2007
  • December 2006
  • July 2006
  • February 2006
  • January 2006
  • March 2001
  • March 1999
  • February 1998
  • August 1996
  • July 1996

Meta

  • Log in

Categories

  • Estate Planning and Probate
  • Planning for Tax Minimization

Law Firm Attorney WordPress Theme By Themespride