News & Analysis as of

Foreign Financial Accounts OVDP

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

Collins Reminds that Corrective Actions Alone do not Always Negate Willful FBAR Penalties

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As a general matter, the FBAR is not a difficult tax form to prepare, at least for most taxpayers and their tax professionals. At its very basics, it merely asks for identifying information regarding the taxpayer and certain...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

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

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?

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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

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

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

Fox Rothschild LLP

Despite Closure Of OVDP, Offshore Tax Evasion Crackdown Marches On

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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

Baker Donelson

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

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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

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

Carlton Fields

Get Ready: IRS To End OVDP

Carlton Fields on

Recently, I discussed the impact of so-called “soft letters” sent by the IRS to various groups of taxpayers with offshore asset disclosure compliance issues....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

Offshore Tax Evasion Rounds Out IRS Annual “Dirty Dozen” For 2018

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The Internal Revenue Service has issued a warning to taxpayers about avoiding taxes by hiding money or assets in unreported offshore accounts, a tax scam that remains on the annual “Dirty Dozen” for 2018. Offshore tax...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

BakerHostetler

IRS Offshore Voluntary Disclosure Program: The Party Is Ending

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On March 13, the Internal Revenue Service announced that the Offshore Voluntary Disclosure Program (OVDP) will come to an end on Sept. 28, 2018. By making this announcement now, the IRS is giving taxpayers with undisclosed...more

Perkins Coie

IRS Announces End to Offshore Amnesty Program

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The IRS recently announced that it would end the Offshore Voluntary Disclosure Program (OVDP). The OVDP is an amnesty program that tens of thousands of taxpayers have used since 2009 to report previously undisclosed foreign...more

Pierce Atwood LLP

IRS Ends Offshore Account Voluntary Disclosure Program

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The IRS recently announced that it is ending its Offshore Voluntary Disclosure Program (OVDP) on September 28, 2018. ...more

Orrick, Herrington & Sutcliffe LLP

IRS To Terminate The Offshore Voluntary Disclosure Program

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

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