Pre-Clearance

News & Analysis as of

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

2014 Changes to the Minnesota Business Corporation Act

On April 25, 2014, Governor Mark Dayton signed House Bill H.F. No. 2190, which makes a number of changes to Chapter 302A of the Minnesota Statutes, the Minnesota Business Corporation Act (the “MBCA”). These changes will go...more

OVDI Pre-Clearance Letters And Their Revocability

The first step a taxpayer with undisclosed or unreported offshore accounts or assets undertakes in seeking to enter the Offshore Voluntary Disclosure Initiative (OVDI) is to apply for pre-clearance from the IRS Criminal...more

Bank Leumi Snafu Jeopardizes DOJ-IRS Offshore Enforcement Initiatives

Three times over the past four years, the IRS has given taxpayers with undisclosed offshore accounts the opportunity to come clean and avoid prosecution. While the most recent offer – the 2012 Offshore Voluntary Disclosure...more

DOJ Revokes Some Pre-Clearances for Bank Leumi Depositors

A recent press release should send a shudder to some voluntary disclosure participants. It should frighten some tax preparers and their clients....more

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