OVDP

News & Analysis as of

November 2014: White Collar Litigation Update

The Future of the Department of Justice’s High Visibility Offshore Tax Evasion Initiative. On August 29, 2013, the U.S. Department of Justice (“DOJ”) Tax Division announced the Program for Non-Prosecution Agreements...more

Orwell’s 1984 30 Year Later

Welcome to 1984 30 years later! One of the most famous quotes from George Orwell’s 1984 is “Big Brother is Watching You.”. This quote is more true now than at any time in past. At the just concluded Global Forum on Tax...more

U.S. Will Disclose Swiss Bank Information

The Department of Justice (DOJ) recently made demand of 106 Swiss banks for information and cooperation under the terms of proposed Non-prosecution agreements (NPA). Non-prosecution agreements were offered to Swiss banks in...more

Tax Law Blog: IRS Revises Offshore Voluntary Compliance Programs

As of July 1, 2014, the Internal Revenue Service (IRS) has implemented several changes to the streamlined filing procedures for offshore compliance, as well as the Offshore Voluntary Disclosure Program (OVDP). These programs...more

IRS Modifies Offshore Filing Procedures

The IRS has issued FAQs relating to the new streamlined procedures for offshore compliance, and for Delinquent International Information Return Submission Procedures....more

IRS Clarifies Requirements for Streamlined Filing Procedures

On October 9, 2014, the Internal Revenue Service published additional guidance clarifying the requirements for participation in the Streamlined Filing Compliance Procedures. (See prior coverage of the new procedures...more

Put Another Notch in the DOJ Gun

In the history of the old west when gun fighters survived a gun fight they might put a “notch” in their pistol as a badge of honor. Well the U.S. Department of Justice can put another notch in its weapon of choice, threat of...more

Offshore Voluntary Discloure; Is it too late

September 15, 2014 is an important for taxpayer who maintained accounts at any of 106 Swiss banks (participating banks) that are participating in the Department of Justice non-prosecution program. Here is why....more

IRS Updates to the Streamlined Compliance Procedures under the Offshore Voluntary Disclosure Program: New Forms Standardize the...

On June 18, 2014, the IRS announced sweeping changes to the 2012 Offshore Voluntary Disclosure Program (OVDP). Since that time, additional clarification on procedural requirements has been issued. Most recently, as of August...more

What Financial Advisers and Accountants Should Know About Expanded IRS Streamlined Filing Compliance Procedures for U.S. Taxpayers...

The Internal Revenue Service (IRS) recently announced “major changes” to its offshore compliance programs, including the Streamlined Filing Compliance Procedures (Streamlined Procedures), the delinquent international...more

What Does a Fiduciary Do When Advised of an Offshore Account?

On June 18, 2014 the IRS announced changes to the Offshore Voluntary Disclosure Program (OVDP). The changes include the following...more

Forget About Hiding Money Offshore!

On July 21, 2014 the OECD released the full version of a new global standard for the exchange of financial information in tax matters “OECD\Standard for Automatic Exchange of Financial Account Information in Tax Matters”...more

Beyond Switzerland: Preparing for the Fallout from FATCA and Other Global Transparency Initiatives

You have implemented FATCA; what comes next? Will your company be the next witness in a US tax investigation? Financial institutions around the world must now prepare to respond to anticipated inquiries and investigations as...more

Part VI – Willful Or Non-Willful Offshore Omissions & Conclusion

Below is Part 6 and the conclusion of my partner, Rick Josepher’s, analysis of the new offshore enforcement environment in light of the new 2014 Offshore Voluntary Disclosure Procedures....more

Part V - Minimizing Risk Of Criminal Prosicution By Meeting Requirements For A Voluntary Discover In IRM 9.5.11.9

Below is Part 5 of my partner, Rick Josepher’s, analysis of the new offshore enforcement environment in light of the new 2014 Offshore Voluntary Disclosure Procedures....more

Tax Talk -- Volume 7, No. 2 -- July 2014

In This Issue: - As FATCA Begins, IRS Rolls out Withholding Forms, Increases IGA Count - IRS Issues Final Circular 230 Rules Simplifying Written Tax Advice Requirements - Mortgage CCA Raises More...more

Streamline Certification Advice

Effective July 1, 2014 new Streamline Procedures for voluntary disclosures may provide some taxpayers the opportunity to pay a substantially reduced or no penalty FBAR penalty depending upon whether they are domestic or...more

Part 4 - The Delinquent International Return Submission Procedured

Here is Part 4 of my partner, Rick Josepher’s, analysis of the new offshore enforcement environment in light of the new 2014 Offshore Voluntary Disclosure Procedures. ...more

Part 3 – The Delinquent FBAR Submission Procedures

Below is Part 3 of my partner, Rick Josepher’s, analysis of the new offshore enforcement environment in light of the new 2014 Offshore Voluntary Disclosure Procedures....more

IRS Announces Changes to the Offshore Voluntary Disclosure Program

As you may have read, the Internal Revenue Service (“IRS”) recently announced changes to its offshore voluntary disclosure programs and announced new options for taxpayers to come into compliance with their U.S. tax...more

Focus on Tax Controversy and Litigation - July 2014

In this issue: - Supreme Court Limits Taxpayer’s Ability to Examine the IRS at a Summons Enforcement Hearing - Court Determines Tax Analysis not Protected by Attorney-Client Privilege and Work Product Doctrine...more

IRS’s Offshore Voluntary Disclosure Program: Current Streamlined Procedure

U.S. citizens and tax residents are required to report their world-wide income on their federal income tax returns. In addition, these U.S. persons are required, and have been required for some time, to separately report...more

Part 2 - The IRS’ New 2014 Offshore Volunteer Disclosure Procedures

Below is Part 2 of my partner, Rick Josepher’s, analysis of the new offshore enforcement environment in light of the new 2014 Offshore Voluntary Disclosure Procedures. To view this Part, and all prior parts, in PDF format...more

Can an OVDP Participant Set Aside a Closing Agreement on the Theory of Duress?

It has been just over five years since the Internal Revenue Service (“IRS”) offered the first of three offshore voluntary disclosure programs for individuals with undisclosed foreign financial accounts. Since the announcement...more

The IRS’ New 2014 Offshore Voluntary Disclosure Procedures (Part 1)

Last weekend I published the introduction to my partner, Rick Josepher’s, analysis of the new offshore enforcement environment in light of the new 2014 Offshore Voluntary Disclosure Procedures. Below is Part 1 of his 6 part...more

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