OVDP

News & Analysis as of

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

How Does the IRS Determine if Conduct is "Willful" or "Non-Willful"?

This Article is a guide for practitioners and taxpayers in deciding whether to apply for the streamline procedures of the IRS's Offshore Voluntary Disclosure Program ("OVDP"). The streamline procedures require a certification...more

New Option for Late FBARs – Just File It!

An often overlooked filing obligation is the annual June 30 requirement to file the FBAR form for taxpayers with foreign bank accounts aggregating over $10,000. Late FBARs are a consistent problem and the IRS has a long...more

Delinquent FBAR Reporting and How to Come Forward? Fact and Choice of Method Really Matter!!!

FBARS for 2014 are Due and MUST BE FILED by June 30, 2015 - There are three approaches to coming forward and filing delinquent FBAR's (Report of Foreign Financial Account). They are...more

Didn’t File an FBAR? Don’t Panic

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

Two More Swiss Banks Reach Resolutions with U.S. Government

Today the Justice Department announced that Société Générale Private Banking (Suisse) SA (SGPB-Suisse) and Berner Kantonalbank AG (BEKB), have reached resolutions under the department’s Swiss Bank Program. With today’s...more

Two More Banks Reach Resolutions Under Justice Department’s Swiss Bank Program

On June 3, 2015, the Justice Department announced that two more Swiss banks, Rothschild Bank AG and Banca Credinvest SA, reached resolutions under the DOJ Swiss Bank Program. Yesterday’s announcement brings the total Swiss...more

What To Do If You Have Delinquent International Information Tax Returns

A U.S. taxpayer with international holdings and interests may not be fully compliant with U.S. tax reporting obligations even though they have currently reported all foreign source income on their annual tax return, filed...more

Global Tax Enforcement in 2015: What You Need to Know

Tax fraud occurs on a considerable scale that can exceed law enforcement’s ability to detect and punish the conduct. This is true at both the federal and state levels. As of 2015, the Internal Revenue Service (“IRS”) and the...more

DOJ Announces Four More Swiss Bank Resolutions

Last week, the Justice Department announced that it had reached resolutions with four more Swiss banks under the terms of the DOJ Swiss Bank Program. The latest banks to resolve their U.S. tax issues are the following: ...more

Foreign Banks and Bankers Face New Risks From Swiss Bank Amnesty

The first non-prosecution agreement signals expanded US tax enforcement opportunities at home and abroad. The US Department of Justice (DOJ) has announced the first non-prosecution agreement (NPA) with BSI, SA, (BSI)...more

DOJ Announces First Non-Prosecution Agreement Under the Swiss Bank Program

On March 30, 2015, the U.S. Department of Justice (DOJ) announced that it reached the first non-prosecution agreement under the Swiss bank program with BSI, S.A. (BSI). BSI, one of Switzerland's ten largest banks, has agreed...more

BSI Account Holders Now Face 50 Percent Penalty On All Undisclosed Offshore Accounts

On Monday, March 30, 2015, the Department of Justice (the "Department") announced its first settlement under the Swiss Bank Program, potentially exposing thousands of U.S. taxpayers to a steep 50 percent penalty for failure...more

First bank resolution announced by DOJ: US taxpayers advised that time is running out to come forward

On March 30, 2015, the US Department of Justice announced the first non-prosecution agreement entered into by a Swiss bank pursuant to the Swiss Bank Program and advised US taxpayers with secret offshore bank accounts that...more

What Expats Need to Know Now about their Taxes, FATCA and the IRS

Are you an American abroad living in perpetual fear of the IRS? Do you wake up every morning wondering if today you’ll receive a formidable notice that the taxman cometh? You are not alone. ...more

Dealing with Erroneous FATCA Inquiries

A foreign bank asks our client to provide information that the bank is not required to provide IRS under FATCA. There are two possibilities. Our client can provide the information or our client can choose not to provide the...more

IRS Clarification on Non-Willful Conduct Certification for Streamlined Offshore Compliance Procedures: Revisions to IRS Forms...

Many U.S taxpayers are often surprised to discover that they have a U.S. tax reporting obligation on financial accounts or assets held overseas. Once they discover their obligation, there are a number of programs through...more

IRS Clarifies Requirements for Establishing Non-Willful Conduct in Offshore Disclosure Cases

Voluntary disclosure programs exist for taxpayers that are not in compliance with their tax and information reporting obligations with respect to foreign bank accounts and assets. The Internal Revenue Service (IRS) recently...more

IRS Announces That More Than 50,000 Have Enrolled In OVDP; Amnesty Program To Remain Open Indefinitely

Yesterday, the Internal Revenue Service unveiled its latest statistics on participation in its Offshore Voluntary Disclosure Program (OVDP), an amnesty program for taxpayers with undisclosed foreign bank accounts that has...more

Should You Consider Making a Domestic Voluntary Disclosure?

Voluntary Disclosures take two forms, Offshore and Domestic. There has been a great deal of attention paid to Offshore Voluntary Disclosure Programs, but little attention has been paid to the Domestic program....more

175 Results
|
View per page
Page: of 7

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.
×