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Reporting Requirements OVDP

Allen Barron, Inc.

The High IRS Tax Rates on a Foreign Trust

Allen Barron, Inc. on

Are you concerned about the high IRS tax rates on a foreign trust? It is important to understand the tax and reporting consequences on this specific type of investment. It may very well be time to evaluate the net value of...more

Freeman Law

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

Freeman Law on

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...

Freeman Law on

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

Gray Reed

Non-Willful FBAR Penalties Will be Much Higher in the Fifth Circuit

Gray Reed on

On November 30, 2021, the Fifth Circuit parted ways with the taxpayer friendly decision of the Ninth Circuit that non-willful penalties are capped at $10,000 per FBAR filing instead of the $10,000 per unreported bank account...more

Freeman Law

IRS Gets Green Light to Seek Information from Third Parties Regarding Panama Offshore Legal Services

Freeman Law on

On July 29, 2021, the United States Attorney for the Southern District of New York, the Assistant Attorney General for the Department of Justice Tax Division, and the IRS Commissioner all announced that a federal court in New...more

Polsinelli

Timely FBAR Filing as Important as Ever Following Circuit Court Decisions

Polsinelli on

Last week the Ninth Circuit issued a win for taxpayers in US v. Boyd, limiting penalties for non-willful violations of the requirement to file a Report of Foreign Bank and Financial Accounts (FBAR). ...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

Foodman CPAs & Advisors

El Nudo Corredizo se está Cerrando

Ahora que el IRS lleva cuatro años intercambiando datos de FATCA en sus computadoras y se está embarcando en una Campaña de Exactitud de Presentación de FATCA, existe una urgencia especial para los Contribuyentes...more

Foodman CPAs & Advisors

The Noose is Closing

Now that IRS has four years of FATCA exchanged data in its computers and is embarking on a FATCA Filing Accuracy Campaign, there is a special urgency for noncompliant U.S. Taxpayers that did not previously exist....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

Snell & Wilmer

IRS Amends Program for Offshore Voluntary Disclosures

Snell & Wilmer on

On September 28, 2018, the Internal Revenue Service (IRS) ended its 2014 Offshore Voluntary Disclosure Program (OVDP). The 2014 OVDP (which was an extension of the 2009 and 2011 OVDPs) was meant to allow taxpayers who...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?

Fox Rothschild LLP on

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

Dickinson Wright on

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

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

Fox Rothschild LLP on

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 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

Dickinson Wright on

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

Butler Snow LLP on

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

Baker Donelson

The Perils Facing a U.S. Person Having an Undeclared Offshore Financial Account

Baker Donelson on

There are legal and financial consequences to any U.S. person who underreports their income. Moreover, similar consequences may exist even in a situation in which all income is reported, yet certain information returns are...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

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