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Foreign Bank Account Report OVDP Foreign Financial Accounts

Freeman Law

Flint Demonstrates the Risks in Trying to Make a Willful IRS Streamlined Filing Non-Willful

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Federal case and after federal case continues to come out providing real-life examples of the pitfalls of filing a Streamlined Filing Compliance Procedure (“SFCP”) with the IRS when the facts suggest willfulness rather than...more

Freeman Law

Collins Reminds that Corrective Actions Alone do not Always Negate Willful FBAR Penalties

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As a general matter, the FBAR is not a difficult tax form to prepare, at least for most taxpayers and their tax professionals. At its very basics, it merely asks for identifying information regarding the taxpayer and certain...more

Freeman Law

IRS Gets Green Light to Seek Information from Third Parties Regarding Panama Offshore Legal Services

Freeman Law on

On July 29, 2021, the United States Attorney for the Southern District of New York, the Assistant Attorney General for the Department of Justice Tax Division, and the IRS Commissioner all announced that a federal court in New...more

Polsinelli

Timely FBAR Filing as Important as Ever Following Circuit Court Decisions

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Last week the Ninth Circuit issued a win for taxpayers in US v. Boyd, limiting penalties for non-willful violations of the requirement to file a Report of Foreign Bank and Financial Accounts (FBAR). ...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Recent IRS Interim Guidance Provides That It Is Not Too Late For Your Willful Clients To Voluntarily Disclose Their Offshore...

The Internal Revenue Service has had a long-standing practice of providing taxpayers with potential criminal exposure a means to come into compliance with the law and potentially avoid criminal prosecution through the making...more

Fox Rothschild LLP

The New IRS Voluntary Disclosure Regime: Worth The Price Of Admission?

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Following the termination last fall of its immensely successful Offshore Voluntary Disclosure Program (OVDP), the Internal Revenue Service (IRS) has announced a new regime to govern all voluntary disclosures regarding tax...more

Orrick, Herrington & Sutcliffe LLP

IRS Outlines New Process for Voluntary Disclosures

On November 29, 2018, the Internal Revenue Service (the "IRS") published a memorandum (the "Memorandum") dated November 20, 2018, outlining the new process for all voluntary disclosures, both domestic and offshore (the "New...more

Blank Rome LLP

IRS Announces New Voluntary Disclosure Procedures

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The Internal Revenue Service (“IRS”) has released a memorandum outlining new procedures for making voluntary disclosures of tax noncompliance, just two months after their 2014 Offshore Voluntary Disclosure Program had ended....more

Rosenberg Martin Greenberg LLP

Offshore Update: IRS Releases Memorandum Addressing Updates to Voluntary Disclosure Practice After Closing Offshore Voluntary...

Now, More than Ever, Taxpayers with Lingering Offshore Tax Non-Compliance Must Seek Professional Assistance - On November 20, 2018, the Internal Revenue Service (“the Service”) released a memorandum containing important...more

Baker Donelson

The Perils Facing a U.S. Person Having an Undeclared Offshore Financial Account

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There are legal and financial consequences to any U.S. person who underreports their income. Moreover, similar consequences may exist even in a situation in which all income is reported, yet certain information returns are...more

McNees Wallace & Nurick LLC

IRS Announces the End of the Offshore Voluntary Disclosure Program

On March 13, 2018, the Internal Revenue Service announced that it will begin to ramp down the 2014 Offshore Voluntary Disclosure Program (“OVDP”) and will close the program on September 28, 2018. The OVDP is currently offered...more

White and Williams LLP

IRS Announces Significant Changes to Offshore Account Disclosure Programs

White and Williams LLP on

The Internal Revenue Service (IRS) recently announced significant changes to its Offshore Voluntary Disclosure Program (OVDP), which it first offered in 2009. The IRS revised OVDP over the years, including introducing the...more

Foodman CPAs & Advisors

At any time during 2017, did you have a financial interest in or signature authority over a financial account (such as a bank...

On April 9, 2018, IRS released Notice (IR-2018-87) to remind Taxpayers that hold foreign assets of their U.S. tax obligations which could include a filing requirement and a U.S. tax liability. This Notice applies to all U.S....more

Foodman CPAs & Advisors

Los Contribuyentes con Cuentas Extranjeras No Divulgadas deben ACTUAR AHORA. El Programa de Divulgación Voluntaria de Cuentas en...

El 13 de marzo del 2018, el IRS anunció la terminación del Programa de Divulgación Voluntaria De Cuentas en el Extranjero (“OVDP”) desde el 28 de septiembre del 2018 (Notificación IR-2018-52). El OVDP ha estado disponible...more

Foodman CPAs & Advisors

Taxpayers with undisclosed foreign accounts need to COME FORWARD NOW. Offshore Voluntary Disclosure Program Ends September, 2018

On March 13, 2018, IRS announced the termination of the Offshore Voluntary Disclosure Program (OVDP) as of September 28, 2018 (Notice IR-2018-52). ...more

BakerHostetler

IRS Offshore Voluntary Disclosure Program: The Party Is Ending

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On March 13, the Internal Revenue Service announced that the Offshore Voluntary Disclosure Program (OVDP) will come to an end on Sept. 28, 2018. By making this announcement now, the IRS is giving taxpayers with undisclosed...more

Perkins Coie

IRS Announces End to Offshore Amnesty Program

Perkins Coie on

The IRS recently announced that it would end the Offshore Voluntary Disclosure Program (OVDP). The OVDP is an amnesty program that tens of thousands of taxpayers have used since 2009 to report previously undisclosed foreign...more

Orrick, Herrington & Sutcliffe LLP

IRS To Terminate The Offshore Voluntary Disclosure Program

On March 13th, the Internal Revenue Service ("IRS") announced that the offshore voluntary disclosure program ("OVDP"), which was first launched in 2009 and modified several times, will close to new taxpayers after September...more

Cole Schotz

IRS To Close Offshore Voluntary Disclosure Program This September

Cole Schotz on

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

Jones Day

IRS Announces End of Offshore Voluntary Disclosure Program

Jones Day on

On March 13, 2018, the Internal Revenue Service ("IRS") announced that the Offshore Voluntary Disclosure Program ("OVDP") will end on September 28, 2018. The program has allowed taxpayers to avoid criminal prosecution by...more

Lowndes

IRS Announces End of FBAR Voluntary Disclosure Program

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As I discussed in a prior blog post, if you have more than $10,000 in a foreign bank account, you are obligated to file Form 114 (commonly known as an FBAR). Failure to make this filing can result in significant civil...more

Clark Hill PLC

Disclose Foreign Assets Now: IRS To Discontinue OVDP

Clark Hill PLC on

U.S. individuals and entities are subject to numerous reporting requirements for foreign assets. Failure to comply with such requirements can lead to criminal exposure and significant civil penalties....more

Foodman CPAs & Advisors

Are you a Taxpayer identified by IRS for not Reporting Offshore Financial Assets?

Taxpayers with unreported foreign financial assets and income run the risk of having the Government determine if their conduct was willful or non-willful. The definition of “Willful" or "non-willful” in Taxpayer’s conduct...more

Foodman CPAs & Advisors

FBAR Penalty Amounts are in the “Best Judgement” of an IRS Examiner

The Report of Foreign Bank and Financial Accounts (FBAR) is not a tax form. Its filing is not required by the Internal Revenue Code. It is required by Title 31 of the Code of Federal Regulations. Title 31 is the Bank Secrecy...more

Holland & Knight LLP

The High Cost of Being Noncompliant with the Internal Revenue Code

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The IRS currently offers the following five programs for noncompliant taxpayers: (i) the Offshore Voluntary Disclosure Program (OVDP), (ii) Streamlined Domestic Offshore Procedures, (iii) Streamlined Foreign Offshore...more

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