OVDP

News & Analysis as of

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

Cross-Border Banking and Out-of-this-World Penalties - Dealing with the IRS when you have Foreign Bank Accounts

A United States citizen or resident that owns (or has signatory authority over) an account at a foreign bank with a value in excess of $10,000 annually must file a Report of Foreign Bank and Financial Account (or “FBAR”) with...more

DOJ Tax Division Chief Outlines Enforcement Priorities for 2016

In speech delivered on January 29, 2016, at the American Bar Association’s Tax Section Midyear Meeting, Acting Assistant Attorney General Caroline D. Ciraolo of the Justice Department’s Tax Division recapped her agency’s...more

What's Your Audit Risk? It Depends!

Taxpayers who are considering one of the Streamline Procedures (Non-resident or Resident) have been advised by the IRS that their returns are subject to the regular audit selection process even though they must identify their...more

Snowden is Only Part of the Disclosure Story

Edward Snowden may have brought attention to telephonic (voice and data) intelligence agencies both U.S and others, but I speculate that his revelations most likely have not changed the bulk of non-criminal or terrorist...more

Offshore Accounts Still Focus of IRS Enforcement

The following Notice from the IRS reiterates the enforcement focus on offshore accounts. Anyone with an unreported offshore account needs to consult counsel and discuss, their compliance options under the "attorney-client...more

Internal Revenue Service Issues Stern Warning To Non-Compliant Taxpayers With Offshore Holdings

Just one day after the October 15 deadline for filing personal income tax returns on extension, the Internal Revenue Service issued a strongly-worded warning to non-compliant taxpayers: take action now to fix your problem, or...more

Justice Department Focusing on Offshore Account

At a recent tax conference a senior Justice Department official reaffirmed the commitment of the U.S. Department of Justice to continue offshore enforcement efforts. As is widely reported the official stated...more

It's Here; The Automatic Exchange of Information Under FATCA Began September 30th

The IRS has announced that as of September 30, 2015 it will implement the automatic exchange of tax information as set forth in the Foreign Account Tax Compliance Act, (FATCA). The IRS Commissioner in announcing the...more

FATCA Update: Treasury Relaxes September 30 Deadline for Model 1 IGA Jurisdictions to Exchange Tax Information

With less than two weeks remaining until many countries are required to exchange tax information with the U.S. pursuant to the Foreign Account Tax Compliance Act (FATCA), the U.S. has agreed to provide partner jurisdictions...more

Bad Bad, Bad Penalty, Bad OVDP Policy

There are now 50 foreign financial institutions on the IRS list of "bad banks" The list is published at the following link...more

Can Spys and Criminals Make Voluntary Disclosures?

A recent article about convicted spy Jonathan Pollard speculated about the effects on his parole if he had an unreported foreign financial account. The simple truth is that Mr. Pollard would be ineligible for the Offshore...more

Justice Department Announces That Three More Swiss Banks Reach Agreements Over Tax Evasion Claims

On July 30, 2015, the Justice Department’s Tax Division announced that three more Swiss banks — PKB Privatbank AG, Falcon Private Bank AG and Credito Privato Commerciale in liquidazione SA (CPC) – have cut deals with the U.S....more

IRS-State Information Sharing Agreements

The IRS published a list of Information Exchange agreements it has with state agencies, a copy of which is available here IRS State Information Exchange Table.pdf The disclosure of this list may help taxpayer's and...more

When the Fifth Amendment Privilege Doesn't Work-Tax Cases

A recent decision of the Third Circuit Court of Appeals illustrates the futility of expecting that the Fifth Amendment Privilege Against Self-incrimination will shield taxpayers from production of offshore financial records. ...more

IRS Guidance on FBAR Penalties

On May 13, 2015, the IRS issued interim guidance to its examiners regarding penalties for failure to timely file the Report of Foreign Bank and Financial Accounts (FBAR). By no later than May 13, 2016, this interim guidance...more

State Offshore Voluntary Disclosure Laws Surveyed

The IRS and the states have mutual exchange of information agreements. The agreements are often bi-directional, so that state information about audit results, often including sales tax audits, is provided to the IRS just as...more

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