On February 28, 2023, in a significant tax case, Bittner v. US, the U.S. Supreme Court held that a U.S. person who fails to file his or her FBAR on a non-willful basis only is subject to a single penalty on the failure to...more
On March 13, 2018, the IRS announced that the Offshore Voluntary Disclosure Program (OVDP) will be closing on September 28, 2018. This program has been in place since 2009.
In general, US persons, that is, citizens and...more
The existing OVDP has been in place since March 2009. The program allows a taxpayer to voluntarily come into compliance with US tax reporting obligations and pay a reduced civil penalty rather than facing either greater...more