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Foreign Bank Account Report OVDP Offshore Funds

Freeman Law

What 2022 Has Taught Us About FBAR Willfulness

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The Bank Secrecy Act requires certain taxpayers to submit timely FBARs to the United States reporting their interests in foreign accounts. If a taxpayer has an FBAR filing requirement and misses it, the taxpayer can be...more

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

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

Gray Reed

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

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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

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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

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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

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

IRS: Las Cuentas Financieras “Offshore” NO pasarán Inadvertidas

El 15 de marzo del 2019, el IRS informó que la ocultación de dinero o activos en cuentas extraterritoriales (“offshore”) no declaradas permanece en la lista de las estafas tributarias conocidas come la Docena Sucia o "Dirty...more

Foodman CPAs & Advisors

IRS: Offshore Financial Accounts will NOT go Unnoticed

On March 15, 2019, IRS reported that hiding money or assets in unreported offshore accounts remains on the Internal Revenue Service’s “Dirty Dozen” list of tax scams for 2019....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

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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

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

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

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

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

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

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

Rosenberg Martin Greenberg LLP

Ruling Provides for Significant Limitation on Amount of Penalties

On May 15, 2018, the United States District Court for the Western District of Texas issued an important ruling concerning the application of willful FBAR penalties under 31 U.S.C. § 5321. In United States v. Colliot, Case...more

Rosenberg Martin Greenberg LLP

What to Do (and Not Do) to Resolve Your Offshore Tax Issues

In recent months, the Internal Revenue Service (“the Service”) began the process of issuing follow-up letters to taxpayers who either requested preclearance to participate in the Offshore Voluntary Disclosure Program (“OVDP”)...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

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

Fox Rothschild LLP

Internal Revenue Service Reminds Taxpayers To Report Offshore Bank Accounts On FBAR Form

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The Internal Revenue Service has issued its annual reminder to taxpayers that they report their foreign assets on their individual tax returns due on April 17, 2018. Individuals with offshore assets such as bank accounts...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

Foodman CPAs & Advisors

Taxpayers with undisclosed foreign accounts need to COME FORWARD NOW. Offshore Voluntary Disclosure Program Ends September, 2018

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

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