"Voluntary Disclosure Program"

Tax Compliance Update: IRS Aggressively Pursues Foreign Banks; Offshore Voluntary Disclosure Program to Remain Open Indefinitely

by Fuerst Ittleman David & Joseph, PL on 5/15/2013

...ean National Bank and how it could affect foreign account holders in the U.S. We went on to discuss the IRS’s Offshore Voluntary Disclosure Program (“OVDP”), how it worked, and some issues that foreign account holders and foreign entities should consider when ... more

Americans Report Hidden Income Under Quiet Disclosure Agreements

by Joseph Donegan on 5/13/2013

...er of individuals reporting hidden income is on the rise, but some may be relying on another reporting method instead of the voluntary disclosure program. ... more

IRS Issues “John Doe Summons” to Wells Fargo Seeking Identities of U.S. Taxpayers with Offshore Accounts at First Caribbean International Bank

by Fuerst Ittleman David & Joseph, PL on 5/9/2013

... - On April 30, 2013, the United States Department of Justice issued a “John Doe Internal Revenue Code” summons to Wells Fargo Bank, as a provider of correspondent bank services for Canadian Imperial Bank of Commerce’s First Caribbean International Bank (“FCIB”), requiring it to turn over records relating to... more

OVDI Pre-Clearance Letters And Their Revocability

by Charles (Chuck) Rubin on 5/8/2013

... Ketcham, Brian P., Can IRS Be Trusted? A Troubling New Development in the Offshore Voluntary Disclosure Program, Journal of Taxation, Apr 2013 ... more

Focus - Spring 2013

by Burns & Levinson LLP on 5/6/2013

... This Issue: - IRS Audits: Understanding Criminal Rights and Risks - Amazing Clients®: Ravago: A Big Company with a Low Profile - When is a Mom not a Mom?: De Facto Parenting in Massachusetts - Can the Private Sector Help Solve the Infrastructure Funding Gap? - Excerpt from IRS Audits: Understanding Criminal Rights and... more

Sutherland SALT Shaker: April 2013 Digest

by Sutherland Asbill & Brennan LLP on 5/1/2013

... this issue: - California Court of Appeal: No Man May Profit From His Own Wrongdoing in a Court of Justice - The (True) Object of My Affection: A Nontaxable Stock Screening Service - Alternate Universe in Colorado: Financial Institution Allowed to Use Alternative Apportionment - Double-Dipping in Delaware: Delaware... more

Bank Leumi Snafu Jeopardizes DOJ-IRS Offshore Enforcement Initiatives

by Morvillo Abramowitz Grand Iason & Anello P.C. on 5/1/2013

...offshore accounts the opportunity to come clean and avoid prosecution. While the most recent offer – the 2012 Offshore Voluntary Disclosure Program (OVDP) – remains open indefinitely, the IRS's recent decision to disqualify approximately 50 taxpayers who disclosed B... more

Reasonable Cause Explained

by Sanford Millar on 4/22/2013

... often find themselves facing substantial penalties for failing to file or late payment of income estate or gift tax return. Some taxpayers face enormous penalties for failing to file a Report of Foreign Bank or Financial Account, commonly known as an FBAR. Penalties, can include the risk of prosecution, and for some possible deportation. There is... more

Judicial Review Applications Challenging Minister’s Alleged Violation Of Voluntary Disclosure Policy And MAP Agreement Allowed To Proceed: Sifto Canada Corp. V. MNR

by Dentons on 4/15/2013

... (a) assess penalties contrary to the terms of the Voluntary Disclosure Program; and ... more

OVDP or 50% FBAR Willfulness Penalty; It is Your Choice

by Sanford Millar on 4/15/2013

...not recommend a probationary sentence as part of a criminal plea agreement. The rationale is that there have been 3 offshore voluntary disclosure programs, 2009,2011 and 2012, which gave and, in the case of 2012 continue to give, taxpayers an opportunity to come forward without... more

The 50% FBAR Penalty, Are you at Risk?

by Sanford Millar on 4/1/2013

...’s who have failed to file FBAR for years prior to 2012 and who have failed to come forward and enter the Offshore Voluntary Disclosure Program (“OVDP”). The reasons why are as follows: ... more

New IRS Offshore Voluntary Disclosure Forms

by Looper Reed & McGraw, P.C. on 3/25/2013

... Form 14454 - Offshore Voluntary Disclosure Program Letter Attachment ... more

Son of FATCA – Swiss/U.K. Agree on Information Exchange

by Sanford Millar on 3/25/2013

...eployed will surely make disclosure the best choice. There is still time to come forward and participate in the IRS Offshore Voluntary Disclosure Program (OVDP). But, as the certainty of discovery increases, the longevity of the OVDP may be in doubt. ... more

Tax Communiqué: Highlights from the Budget 2013

by Heenan Blaikie LLP on 3/22/2013

...Budget 2013 was tabled on March 21, 2013. Heenan Blaikie’s National Tax Group has prepared the following overview of some of the more significant tax-related measures.... more

DOJ Revokes Some Pre-Clearances for Bank Leumi Depositors

by Sanford Millar on 3/11/2013

...tem.” Therefore, the pre-clearances may have been issued in error. But what follows from the disqualification from the voluntary disclosure program is of general application to all U.S. taxpayers who have undisclosed offshore accounts. ... more

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Legal updates for: "Voluntary Disclosure Program"