News & Analysis as of

OVDP

Allen Barron, Inc.

The High IRS Tax Rates on a Foreign Trust

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Are you concerned about the high IRS tax rates on a foreign trust? It is important to understand the tax and reporting consequences on this specific type of investment. It may very well be time to evaluate the net value of...more

Freeman Law

What 2022 Has Taught Us About FBAR Willfulness

Freeman Law on

The Bank Secrecy Act requires certain taxpayers to submit timely FBARs to the United States reporting their interests in foreign accounts. If a taxpayer has an FBAR filing requirement and misses it, the taxpayer can be...more

Freeman Law

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

Freeman Law on

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

Common Mistakes in Submitting an IRS Streamlined Filing Compliance Procedure Submission: And a Discussion of Professional...

Freeman Law on

For one reason or another, I had several calls last year with attorneys and others regarding IRS Streamlined Filing Compliance Procedure submissions gone wrong. In most cases, it was evident that the tax professional had...more

Freeman Law

Criminal Tax Statutes of Limitations and Suspensions: 18 U.S.C. § 3292 and the Fifth Circuit’s Decision in Pursley

Freeman Law on

In civil and in criminal cases, the Government must generally act within a certain prescribed time to take action against taxpayers. In legal parlance, this period of time is known as the “statute of limitations.” The...more

Freeman Law

Is My Foreign Retirement Account Subject to IRS Information Return Reporting (FBAR, 3520, etc.)?

Freeman Law on

United States citizens and residents[i] are subject to federal income tax on their worldwide income. For example, even if a United States citizen permanently relocates to a foreign country, he or she will generally continue...more

Gray Reed

Non-Willful FBAR Penalties Will be Much Higher in the Fifth Circuit

Gray Reed on

On November 30, 2021, the Fifth Circuit parted ways with the taxpayer friendly decision of the Ninth Circuit that non-willful penalties are capped at $10,000 per FBAR filing instead of the $10,000 per unreported bank account...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

Polsinelli on

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

Foodman CPAs & Advisors

The OVDP is now the VDP

There was an IRS termination of the Offshore Voluntary Disclosure Program (OVDP) on September 28, 2018. On November 20, 2018, following the OVDP notice of termination, there was a release of a Memorandum announcing the...more

Foodman CPAs & Advisors

Did you know that the IRS has 59 Compliance Campaigns? Have your Audit Plan Ready!

Foodman CPAs & Advisors on

IRS Large Business and International (IRS LBI) currently has 59 Active Compliance Campaigns.  The purpose of the IRS compliance campaign strategy is to redefine large business compliance work and build a supportive...more

Foodman CPAs & Advisors

Guilty From The Get-Go In The IRS Updated Voluntary Disclosure Program?

On June 20, 2019, the National Taxpayer Advocate (TA), an independent organization within the IRS that helps taxpayers and protects taxpayer rights, issued a final Report to Congress. A section of the report focused on the...more

Eversheds Sutherland (US) LLP

LB&I aims new campaigns at taxpayers at home and abroad

On July 19, 2019, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced the addition of six compliance campaigns, bringing to 59 the total number of active campaigns. These six...more

Fox Rothschild LLP

59 And Counting: IRS LB&I Announces Six More Compliance Campaigns

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Earlier this week, the Internal Revenue Service’s Large Business & International Division announced six more compliance campaigns, bringing the total number of campaigns announced to date to a whopping 59. These campaigns...more

McDermott Will & Emery

More IRS “Campaigns?! IRS Announces Six More Examination Campaigns

McDermott Will & Emery on

On July 19, 2019, the Internal Revenue Service (IRS) Large Business & International (LB&I) division announced the approval of six new campaigns. As in the past, the IRS stated that “LB&I’s goal is to improve return selection,...more

Foodman CPAs & Advisors

IRS: Las Cuentas Financieras “Offshore” NO pasarán Inadvertidas

El 15 de marzo del 2019, el IRS informó que la ocultación de dinero o activos en cuentas extraterritoriales (“offshore”) no declaradas permanece en la lista de las estafas tributarias conocidas come la Docena Sucia o "Dirty...more

Foodman CPAs & Advisors

IRS: Offshore Financial Accounts will NOT go Unnoticed

On March 15, 2019, IRS reported that hiding money or assets in unreported offshore accounts remains on the Internal Revenue Service’s “Dirty Dozen” list of tax scams for 2019....more

Foodman CPAs & Advisors

El Nudo Corredizo se está Cerrando

Ahora que el IRS lleva cuatro años intercambiando datos de FATCA en sus computadoras y se está embarcando en una Campaña de Exactitud de Presentación de FATCA, existe una urgencia especial para los Contribuyentes...more

Foodman CPAs & Advisors

The Noose is Closing

Now that IRS has four years of FATCA exchanged data in its computers and is embarking on a FATCA Filing Accuracy Campaign, there is a special urgency for noncompliant U.S. Taxpayers that did not previously exist....more

Eversheds Sutherland (US) LLP

LB&I announces new campaigns – Related-party service companies, offshore private banking and loose-filed Forms 5471

On April 16, 2019, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced three new compliance campaigns. The campaigns focus on: ..Transfer pricing for “captive” services...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

Snell & Wilmer

IRS Amends Program for Offshore Voluntary Disclosures

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On September 28, 2018, the Internal Revenue Service (IRS) ended its 2014 Offshore Voluntary Disclosure Program (OVDP). The 2014 OVDP (which was an extension of the 2009 and 2011 OVDPs) was meant to allow taxpayers who...more

Foodman CPAs & Advisors

Streamlined Filing Program for U.S. Taxpayers Residing Outside of the U.S. continues to be available but can be Discontinued at...

After the closing of the Offshore Voluntary Disclosure Program (OVDP) - which ended on September 28, 2018, the US Department of Treasury released a Memorandum on November 20, 2018, disclosing an “Updated Voluntary Disclosure...more

Foodman CPAs & Advisors

Disclosing Voluntarily to the IRS to potentially avoid Criminal Prosecution is still an Option for Taxpayers, but with some...

On September 28, 2018, the IRS closed the Offshore Voluntary Disclosure Program (2014 OVDP). The 2014 OVDP (and prior 2011 and 2009 programs) had the purpose of providing Taxpayers that WILLFULLY failed to report foreign...more

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