Act II: IRS Announces Another Offshore Voluntary Disclosure Program

more+
less-

For years, the Internal Revenue Service (“IRS”) has been aggressively pursuing the disclosure of unreported foreign accounts and assets held by U.S. taxpayers, including offering certain voluntary disclosure programs featuring reduced penalties in exchange for U.S. taxpayer compliance. On February 8, 2011, the IRS announced the details of its latest voluntary disclosure program, known as the 2011 Offshore Voluntary Disclosure Program (the “2011 OVDP”). The 2011 OVDP follows on the heels of a similar program offered in 2009, which, by most accounts, attracted several thousand U.S. taxpayers. Similar to its predecessor, the objective of the 2011 OVDP is to bring U.S. taxpayers that have undisclosed foreign accounts and/or undisclosed foreign entities into compliance with U.S. tax laws.

The 2011 OVDP offers U.S. taxpayers the chance to resolve their U.S. tax liabilities associated with undisclosed foreign accounts and entities through a reduced penalty framework and a minimized chance of criminal prosecution. Although the penalty framework for the 2011 OVDP is generally higher than in 2009, it provides a fixed penalty framework that seems to remove any discretion from IRS examiners to negotiate a different offshore penalty percentage.

Please see full article below for more information.

LOADING PDF: If there are any problems, click here to download the file.

Written by:

more+
less-

Manatt, Phelps & Phillips, LLP on:

JD Supra Readers' Choice 2016 Awards
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.
×
Loading...
×
×