OVDP

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Reporting A Closely Held U.S. Corporation’s Overseas Activities

We have heard a lot about large, publicly-traded U.S. corporations that have parked trillions of dollars overseas to avoid the payment of U.S. income tax. We have heard how the tax system must be seriously broken to have so...more

First LB&I Campaigns Demonstrate a Flexible Approach

On January 31, 2017, the Large Business & International Division of the IRS (LB&I) released the subjects of its first 13 campaigns. Each campaign addresses a specific area that the IRS has identified as a substantial...more

Bankers, Do your US Clients tell you everything that you need to know?

Given the information publicly revealed by “Panama Papers”, and recent IRS reminders to out-of-compliance US Taxpayers to come into full compliance with their federal tax obligations, it is critical that Bankers and Financial...more

The High Cost of Being Noncompliant with the Internal Revenue Code

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

¿Sabe usted por qué y cómo entrar en el Programa de Divulgación Voluntaria de Cuentas en el Extranjero (OVDP)?

A través del Programa de Divulgación Voluntaria de Cuentas en el Extranjero (OVDP – Offshore Voluntary Disclosure Program), el IRS permite a los Contribuyentes que no están en cumplimiento intentionalmente revelar las cuentas...more

Do you know why and how to make an Offshore Voluntary Disclosure?

Through its Offshore Voluntary Disclosure Program (OVDP), IRS permits noncompliant taxpayers to disclose Willfully unreported offshore accounts and related income. The “key” word for OVDP is Willful. Unlike the Streamlined...more

Reckless Indifference Is Enough For Willfullness Finding For Puroses Of FBAR Nonfiling Penalties

A husband and wife had an accounting in Switzerland at UBS AG, into which they deposited commissions from camera sales and also directed some of their international customers to make deposits. In 2007, the tax year at issue,...more

Cuando FATCA y los Programas de Amnistía Fiscal se cruzan, ¿será demasiado tarde para los contribuyentes Estadounidenses?

Instituciones Financieras extranjeras (FFIs) y las autoridades fiscales de los países anfitriones le han proporcionado al IRS con una segunda ronda de informes de información sobre cuentas financieras mantenidas por los...more

When FATCA and Tax Amnesty Programs intersect, will it be too late for US Taxpayers?

Foreign Financial Institutions (FFIs) and host country tax authorities have provided IRS with a second round of information reports on financial accounts held by US Taxpayers. This exchange of information is automated and...more

If you are an “Expat”, or thinking about “Expatriating”, think about this!

Thinking about giving up your US citizenship pending the results of the Presidential election in November 2016? Concerned because you have been an “Expat” for a long time and have not filed US Tax returns? Just realized that...more

Sonhos Interrompidos - Como uma não conformidade tributária pode destruir o Sonho Americano de imigrantes não registrados - Parte...

Panorama - A Parte I desta série teve enfoque no pesadelo e problema imprevisto de declarações de impostos não apresentadas para imigrantes não registrados. As consequências de "empurrar o problema com a barriga"...more

Broken Dreams - How Tax Non-Compliance Can Destroy the American Dream of Undocumented Immigrants - Part 2

Part I of this series focused on the unforeseen nightmare and problem of unfiled tax returns for undocumented immigrants. The consequences of “kicking the can down the road”, will have significant legal and financial...more

Use of Shell Companies To Shield Identity Further Limited

On July 27, 2016 the Financial Crimes Enforcement Network, (FinCEN) of the Department of the Treasury issued expanded Geographic Targeting Orders (GTO) that will...more

Streamline Procedure Risks: Are you really Non-willful?

According to reports in Tax Analysts there have been 54, 000 Offshore Voluntary Disclosure (OVDP) participants 30,000 Streamline Procedure filings. The Streamline Procedure filings are now the subject of intense Department...more

What are the Tax Consequences of BREXIT for U.S. Taxpayers?

Recently, The Harvard Law School Forum on Corporate Governance and Finance published a note titled "The Legal Consequence of Brexit, authored by Simon Witty. We have restated the transactional tax commentary here. We have...more

Hong Kong & Singapore: Awaiting a New DOJ Tax Program for Asian Banks?

As the Department of Justice is wrapping up its prosecution of over a dozen Swiss banks, federal prosecutors and IRS special agents are analyzing a treasure trove of previously undeclared taxpayer account information that...more

IRS Agrees to Increased Enforcement of IRS's Offshore Voluntary Disclosure Program

In a report issued to the Internal Revenue Service International Division and Criminal Division, the Treasury Inspector General for Tax Administration (TIGTA) found that taxpayers trying to avoid criminal charges and...more

“Spider Webs”, “Panama Papers” and IRS

IRS has asked involved U.S. taxpayers to come forward before IRS reads and dissects the “Panama Papers”. IRS will “plan how to use the huge trove of leaked documents to catch criminals — and urged Americans to come clean now...more

Don’t Let The I.R.S. Define Your Conduct As Willful, or Else………

Something that most of us don’t realize is that Internal Revenue Service has stated that the taxpayer is responsible to learn IRS requirements within the historic U.S. framework of a voluntary reporting system. The IRS...more

You Skipped OVDP, now the IRS has initiated an Audit

Since 2009, the Offshore Voluntary Disclosure Program (OVDP) has been available to Taxpayers who have foreign assets, foreign financial accounts, and foreign source income unreported for U.S. Income Tax and Bank Secrecy Act...more

Panama Papers To Be Released May 9, 2016. Why Does It Matter?

The International Consortium of Investigative Journalists (ICIJ) will release perhaps the largest database of private offshore companies and their ultimate owner ever made public. According to the ICIJ...more

As Panama Papers Illustrates, IRS Discovery of Undisclosed Assets Just a Matter of Time

As the recent leak of the "Panama Papers" reminded the world, some secrets don't keep well, particularly those related to undisclosed foreign assets. And once a person's identity is disclosed as a holder of undisclosed...more

Failure to Report Foreign Accounts is Illegal, IRS Warns

Maintaining a foreign bank or other financial account is not illegal. Such accounts are increasingly common, as the globe shrinks. However, in the case of U.S. citizens or residents (and certain non-residents), failing to...more

IRS Changes Streamlined Filing Compliance Procedures for Non-Willfulness Certification Forms

The Internal Revenue Service (IRS) recently modified the non-willfulness certification form that individual taxpayers must submit to enroll in the streamlined filing compliance procedures (SFCP). SFCP is a program offered by...more

When Offshore Asset Protection Fails

What happens when The IRS attacks your offshore asset protection plan? The simple answer is you may face a variety of civil and criminal investigations and penalties. What constitutes an offshore asset protection plan?...more

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