News & Analysis as of

OVDP Voluntary Disclosure

Freeman Law

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

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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

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

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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

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

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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

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

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

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

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

Fox Rothschild LLP

The New IRS Voluntary Disclosure Regime: Worth The Price Of Admission?

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Following the termination last fall of its immensely successful Offshore Voluntary Disclosure Program (OVDP), the Internal Revenue Service (IRS) has announced a new regime to govern all voluntary disclosures regarding tax...more

Dickinson Wright

Updated Voluntary Disclosure Practice Rules

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On September 28, the IRS ended its 2014 Offshore Voluntary Disclosure Program (“OVDP”). The IRS issued a memorandum—dated November 20, 2018—to announce its new Updated Voluntary Disclosure Practice rules. The IRS memorandum...more

Orrick, Herrington & Sutcliffe LLP

IRS Outlines New Process for Voluntary Disclosures

On November 29, 2018, the Internal Revenue Service (the "IRS") published a memorandum (the "Memorandum") dated November 20, 2018, outlining the new process for all voluntary disclosures, both domestic and offshore (the "New...more

Blank Rome LLP

IRS Announces New Voluntary Disclosure Procedures

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The Internal Revenue Service (“IRS”) has released a memorandum outlining new procedures for making voluntary disclosures of tax noncompliance, just two months after their 2014 Offshore Voluntary Disclosure Program had ended....more

Fox Rothschild LLP

IRS Unveils Post-OVDP Voluntary Disclosure Procedures

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The Internal Revenue Service released its long-awaited updated procedures for voluntary disclosures now that the much-heralded Offshore Voluntary Disclosure Program (OVDP) closed on September 28, 2018. The updated procedures...more

Rosenberg Martin Greenberg LLP

Offshore Update: IRS Releases Memorandum Addressing Updates to Voluntary Disclosure Practice After Closing Offshore Voluntary...

Now, More than Ever, Taxpayers with Lingering Offshore Tax Non-Compliance Must Seek Professional Assistance - On November 20, 2018, the Internal Revenue Service (“the Service”) released a memorandum containing important...more

Fox Rothschild LLP

Despite Closure Of OVDP, Offshore Tax Evasion Crackdown Marches On

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On September 29, 2018, the Internal Revenue Service closed for good the long-running Offshore Voluntary Disclosure Program (OVDP), its hugely successful tax amnesty program for undisclosed offshore financial assets. Since...more

Foodman CPAs & Advisors

IRS gives Internal Revenue Manual Voluntary Disclosure Consideration if…….

Foodman CPAs & Advisors on

When IRS reviews a criminal tax case, consideration is given to various factors such as whether a voluntary disclosure was made, whether prosecution exists, the health, age and mental condition of the Taxpayer and whether a...more

Foodman CPAs & Advisors

IRS ENDS OVDP right when some Taxpayers GET IT!

On March 13, 2018, IRS announced the termination of the Offshore Voluntary Disclosure Program (OVDP) as of September 28, 2018 (Notice IR-2018-52). ...more

Dickinson Wright

Offshore Voluntary Disclosure Program (“OVDP”) Ends September 28, 2018

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The IRS issued a reminder on Tuesday, September 4, 2018, that its Offshore Voluntary Disclosure Program (“OVDP”) will end on September 28, 2018. The IRS had previously announced the wind down of the program earlier this...more

Butler Snow LLP

Submit OVDP Preclearance Letter by the End of this Week

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The IRS requires that Offshore Voluntary Disclosure Program (“OVDP”) preclearance letters be submitted to IRS Criminal Investigations by August 24, 2018. Taxpayers only have five more days to submit the OVDP preclearance...more

Bond Schoeneck & King PLLC

Fewer Voluntary Disclosure Options for U.S. Persons with Foreign Assets

The United States Offshore Voluntary Disclosure Program is ending on September 28, 2018. If you are a U.S. citizen living abroad, or you are living in the U.S. but hold foreign assets, this can sound terrifying. This is...more

McNees Wallace & Nurick LLC

IRS Announces the End of the Offshore Voluntary Disclosure Program

On March 13, 2018, the Internal Revenue Service announced that it will begin to ramp down the 2014 Offshore Voluntary Disclosure Program (“OVDP”) and will close the program on September 28, 2018. The OVDP is currently offered...more

Proskauer Rose LLP

Wealth Management Update - May 2018

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May Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The May § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is...more

White and Williams LLP

IRS Announces Significant Changes to Offshore Account Disclosure Programs

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The Internal Revenue Service (IRS) recently announced significant changes to its Offshore Voluntary Disclosure Program (OVDP), which it first offered in 2009. The IRS revised OVDP over the years, including introducing the...more

Carlton Fields

Get Ready: IRS To End OVDP

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Recently, I discussed the impact of so-called “soft letters” sent by the IRS to various groups of taxpayers with offshore asset disclosure compliance issues....more

Foodman CPAs & Advisors

At any time during 2017, did you have a financial interest in or signature authority over a financial account (such as a bank...

On April 9, 2018, IRS released Notice (IR-2018-87) to remind Taxpayers that hold foreign assets of their U.S. tax obligations which could include a filing requirement and a U.S. tax liability. This Notice applies to all U.S....more

Foodman CPAs & Advisors

Los Contribuyentes con Cuentas Extranjeras No Divulgadas deben ACTUAR AHORA. El Programa de Divulgación Voluntaria de Cuentas en...

El 13 de marzo del 2018, el IRS anunció la terminación del Programa de Divulgación Voluntaria De Cuentas en el Extranjero (“OVDP”) desde el 28 de septiembre del 2018 (Notificación IR-2018-52). El OVDP ha estado disponible...more

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