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Supreme Court Rules Non-Willful FBAR Penalties are Calculated on a Per Report Basis

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

IRS To Close Offshore Voluntary Disclosure Program This September

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

Significant Revisions to the IRS Offshore Voluntary Disclosure Program

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

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