News & Analysis as of

Foreign Bank Account Report Compliance OVDP

IRS Guidance on FBAR Penalties

by Hodgson Russ LLP on

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

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

IRS Announces Changes to Its Offshore Voluntary Disclosure and Streamlined Procedures

by Hodgson Russ LLP on

On June 18, 2014, the IRS announced a number of significant changes to its Offshore Voluntary Disclosure Program (OVDP) and 2012 streamlined procedure for nonresidents and the addition of a streamlined procedure for U.S....more

Significant Revisions to the IRS Offshore Voluntary Disclosure Program

by Cole Schotz on

The existing OVDP has been in place since March 2009. The program allows a taxpayer to voluntarily come into compliance with US tax reporting obligations and pay a reduced civil penalty rather than facing either greater...more

Traps Within the new Streamline Offshore Account Disclosure Program

by Sanford Millar on

The new Streamlined Filing Compliance Procedures (the Streamline Procedures) go into effect July 1, 2014. Under the terms of the procedures some taxpayers will suffer no penalty for failure to timely file FBARs, (in the case...more

Offshore Tax Enforcement Update: IRS Unveils Major Changes to Voluntary Disclosure Program

by Blank Rome LLP on

Since the 1970s, U.S. taxpayers with foreign banks accounts have been required to annually report their foreign bank account information to the Department of Treasury on a Report of Foreign Bank and Financial Accounts...more

IRS Changes the Streamlined Filing Compliance Procedures and Offshore Voluntary Disclosure Program (OVDP) - Determining Your Most...

by Holland & Knight LLP on

The IRS announced substantial changes to both the Streamlined Filing Compliance Procedures for Non-Resident, Non-Filer Taxpayers and the Offshore Voluntary Disclosure Program (OVDP) on June 18, 2014....more

IRS Announces Sweeping Changes To Its Offshore Voluntary Disclosure Programs: New Rules Effective July 1, 2014

On Wednesday, June 18, 2014 the Internal Revenue Service announced sweeping changes to its Offshore Voluntary Disclosure Programs, effective Tuesday, July 1, 2014. Some taxpayers are treated much more leniently under expanded...more

IRS Commissioner Hints That OVDP Modifications Are in the Works

by Blank Rome LLP on

Since 2009, the Internal Revenue Service has offered three different amnesty programs for taxpayers with undeclared foreign bank accounts. These programs, the current version of which is entitled the Offshore Voluntary...more

Offshore Disclosure: What Needs To Be Disclosed? A Checklist

by Sanford Millar on

The following is a list of questions that should lead to the discovery of offshore assets, whether properly reported or not. If you answer yes to any of these questions, then you may have filing obligations and should seek...more

The Qualified Quiet Disclosure: Operating Outside Of The IRS Offshore Voluntary Disclosure Initiative

by Moskowitz LLP on

Individuals with previously undisclosed foreign assets and/or income have a variety of options to become compliant with the IRS, with two avenues for resolution being the most common: Qualified Quiet Disclosure and the...more

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