News & Analysis as of September 18, 2024

FinCEN › OVDP

+ Follow

The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of money laundering, terrorist financing and other financial crimes by collecting, monitoring, and analyzing financial transaction data. Such data is disseminated to both domestic and international law enforcement agencies. less -

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

Freeman Law on 9/20/2022

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

IRS Outlines New Process for Voluntary Disclosures

Orrick, Herrington & Sutcliffe LLP on 12/21/2018

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

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

Baker Donelson on 8/10/2018

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

IRS To Terminate The Offshore Voluntary Disclosure Program

Orrick, Herrington & Sutcliffe LLP on 3/23/2018

On March 13th, the Internal Revenue Service ("IRS") announced that the offshore voluntary disclosure program ("OVDP"), which was first launched in 2009 and modified several times, will close to new taxpayers after September...more

Developing a Strategy to Fight FBAR Penalties

Carlton Fields on 5/4/2017

Since 2009, the number of FBAR penalties imposed for failures to report foreign bank accounts and the size of the penalties have both increased dramatically. Originally published in The Tax Advisor....more

Reporting A Closely Held U.S. Corporation’s Overseas Activities

Farrell Fritz, P.C. on 2/14/2017

We have heard a lot about large, publicly-traded U.S. corporations that have parked trillions of dollars overseas to avoid the payment of U.S. income tax. We have heard how the tax system must be seriously broken to have so...more

Failure to Report Foreign Accounts is Illegal, IRS Warns

Ballard Spahr LLP on 4/7/2016

Maintaining a foreign bank or other financial account is not illegal. Such accounts are increasingly common, as the globe shrinks. However, in the case of U.S. citizens or residents (and certain non-residents), failing to...more

FBAR Filing Deadline Approaching

Foley Hoag LLP on 5/19/2014

Reports Due by the End of June - Every U.S. person that had a financial interest in, or signature or other authority over, a foreign financial account during 2013 must electronically file with the U.S. Treasury...more

U.S. Response to Unreported Offshore Income and Assets of U.S. Taxpayers

Eversheds Sutherland (US) LLP on 2/18/2011

Since the G-20 meeting on April 2, 2009, there has been a worldwide emphasis on the elimination of bank secrecy through the implementation of tax information exchange agreements ("TIEA") with countries or jurisdictions that...more

9 Results

View per page

Page: of 1

FinCEN › OVDP

"My best business intelligence, in one easy email…"