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  • IRS Has New Procedures for Scrutinizing Quiet Disclosures
    A Quiet Disclosure occurs when a person intentionally files tax returns (either amended or original returns, FBARs, and/or other International Informational Returns) outside of one of the IRS’ formal voluntary disclosure In other words, the individual submits the returns and hopes to fly below the radar so that the IRS does not discover that the
  • Significant FBAR Penalties Upheld by Court
    Taxpayers have lost and the US Internal Revenue Service has scored a victory over the taxpayer in Kimble v USA, a court case concerning the reporting of foreign bank accounts. The taxpayer, Alice Kimble, held Swiss accounts at both HSBC and UBS in the early 2000s and was not aware until 2008 that she was required to report
  • Analysis: IRS New Disclosure Program
    On November 29, 2018, the IRS released a memorandum that addressed the process for all voluntary disclosures following the end of the Offshore Voluntary Disclosure Program (“OVDP”) on September 28, 2018. The new voluntary disclosure procedure provides uniformity to offshore and domestic voluntary disclosures. The OVDP was initiated in 2009 and was designed to bring
  • New IRS Voluntary Disclosure in 7 Steps
    The following are the seven steps of the new updated IRS voluntary disclosure process: A taxpayer will make a voluntary disclosure preclearance request using IRS Form 14457 to IRS Criminal Investigation (CI). Taxpayers can request preclearance via mail or fax. No need to fear IRS Criminal Investigation (CI)’s involvement since they have always been involved


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