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Income Taxes › Voluntary Disclosure

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Rivkin Radler LLP

Unconstitutionally Excessive FBAR Penalties? It Depends

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You may recall that earlier this year the IRS launched an initiative to pursue 125,000 “high-income, high-wealth” taxpayers who have not filed taxes since 2017. These were cases where the IRS received third party information...more

Foodman CPAs & Advisors

IRS Voluntary Disclosure Practice

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Taxpayers that have willfully failed to comply with tax or tax-related obligations may be able to resolve their non-compliance and limit their exposure to criminal prosecution by filing an application to the IRS Voluntary...more

Allen Barron, Inc.

When to Consider the IRS Voluntary Disclosure Program or VDP

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Are you wondering when a US taxpayer should consider the IRS Voluntary Disclosure Program or VDP? Are you concerned about unreported or under-reported income, financial accounts, assets, investments, cryptocurrency or...more

Mayer Brown

Brazilian IRS Program Incentivizes Disclosure of Certain Tax Liabilities

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On April 3, 2024, the Brazilian Internal Revenue Service (“Brazilian IRS”) published Normative Instruction RFB No. 2,184 (“IN/RFB No. 2,184/2024“), regulating a special program to incentivize the voluntary disclosure of...more

McDermott Will & Emery

Weekly IRS Roundup March 11 – March 15, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 11, 2024 – March 15, 2024. ...more

Fox Rothschild LLP

The Presumption of Innocence Podcast: Episode 28 - Under the Microscope: Examining the Future of the ERC

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The House Ways and Means Committee recently advanced a bill that gives businesses a proposed deadline of January 31, 2024 to file Employee Retention Credit (ERC) claims. This comes on the heels of recent announcements by the...more

Baker Donelson

SALT Select Developments - October 2023

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State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. ln this newsletter edition, we will briefly summarize selected state and local tax (SALT)...more

Freeman Law

The IRS’s Voluntary Disclosure Practice (VDP): IRS Revises Form 14457

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On February 15, 2022, the IRS announced that IRS Form 14457, Voluntary Disclosure Practice Preclearance Request and Application, and the accompanying instructions to the form had been revised. Because the revisions provide...more

Freeman Law

The Evolving Standard of “Willfulness” in FBAR Cases: Where are We Now?

Freeman Law on

The concept of “willfulness” is an important one in the FBAR civil penalty context. Indeed, a taxpayer’s willful failure to file a timely and accurate FBAR may result in significant penalties: the higher of 50-percent of...more

Freeman Law

The IRS’s Renewed Focus on Abusive Trust Arrangements

Freeman Law on

Taxpayers have long utilized trust arrangements for the transfer of wealth to beneficiaries or for the protection of assets from creditors.  Generally, there is nothing nefarious about these types of arrangements.  Rather,...more

Freeman Law

IRS Targets Participants in Malta Pension Plan Transactions

Freeman Law on

This morning, I woke up to news in the Wall Street Journal that indicated that the United States and the Republic of Malta had entered into a Competent Authority Agreement (“CAA”). Generally, this news would not have caught...more

Holland & Knight LLP

Same Statute, Same Form, Different Penalties: Welcome to FBAR Litigation

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The "Report of Foreign Bank and Financial Accounts" (FBAR) penalty has been the subject of much litigation. This Holland & Knight alert focuses on the non-willfulness element of 31 U.S.C. § 5321(a)(5)(B). Both the U.S. Court...more

Freeman Law

Is My Foreign Retirement Account Subject to IRS Information Return Reporting (FBAR, 3520, etc.)?

Freeman Law on

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

McDermott Will & Emery

Key Takeaways | Cryptocurrency Global Tax Enforcement: What Investors and Companies in the Industry Need to Know NOW

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During a recent program discussing the latest government enforcement efforts related to cryptocurrency, we spoke with Gary Alford, one of the leading Internal Revenue Service (IRS) agents in their crypto enforcement efforts,...more

McDermott Will & Emery

[Webinar] Cryptocurrency Global Tax Enforcement: What Investors and Companies in the Industry Need to Know NOW - June 28th, 12:00...

McDermott Will & Emery on

Following the US Internal Revenue Service’s (IRS) announcement of “Operation Hidden Treasure,” companies and individuals should prepare for increased scrutiny of virtual currency transactions. Unveiled in March, the operation...more

Gray Reed

Taxpayer Guidelines for Cryptocurrency in 2021

Gray Reed on

Cryptocurrency is more accessible than ever before. Banks are continuing to both implement procedures for and, in some cases, develop their own cryptocurrencies. Paypal allows users in the U.S. to buy, sell and hold select...more

Foodman CPAs & Advisors

What can I do if I willfully failed to comply with my tax obligations?

Foodman CPAs & Advisors on

Voluntary compliance is the foundation of the US tax system. Although the majority of US Taxpayers voluntarily comply with their obligations, some fail to do so.    ...more

Williams Mullen

Williams Mullen's Comeback Plan: Part I – State & Local Tax (SALT) Compliance During COVID-19: What to Do When You’re Behind

Williams Mullen on

Tax partners Stephanie Lipinski Galland and Kyle Wingfield summarize what you can do if you have not filed your state and local taxes or if you are unable to pay your tax bills due to the COVID-19 pandemic. Topics include...more

Butler Snow LLP

U.S. Internal Revenue Service Updates Voluntary Disclosure Procedures

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The U.S. Internal Revenue Service has finally updated its voluntary disclosure procedures following the closure of the Offshore Voluntary Disclosure Program (the “OVDP”) earlier this year. The updated procedures will apply to...more

Burr & Forman

IRS Releases New Guidance on Voluntary Tax Disclosures

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A bedrock of IRS administrative practice has been the voluntary disclosure. Where an individual or business has not filed tax returns or believes they may have criminal tax exposure for prior actions, IRS procedures have...more

Foodman CPAs & Advisors

IRS gives Internal Revenue Manual Voluntary Disclosure Consideration if…….

Foodman CPAs & Advisors on

When IRS reviews a criminal tax case, consideration is given to various factors such as whether a voluntary disclosure was made, whether prosecution exists, the health, age and mental condition of the Taxpayer and whether a...more

Butler Snow LLP

5 Common Tax Misconceptions Facing U.S. Persons Living Outside the U.S.

Butler Snow LLP on

Living abroad can be a wonderful opportunity for many U.S. Persons, but a few commonly misunderstood aspects of the U.S. tax system directly impact such “expats,” often to their financial detriment. Here are the five most...more

Burr & Forman

IRS Announces End to Foreign Bank Account Disclosure Program: What Can You Do Now If You Still Have Unreported Foreign Bank...

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The IRS recently announced it will be shutting down its successful Offshore Voluntary Disclosure Program (OVDP) for unreported foreign bank accounts and income. The program will end September 28, 2018. Under the OVDP, first...more

Bennett Jones LLP

Disclosure Delayed May Be Disclosure Denied

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New Developments in Voluntary Disclosures - In June 2017, the Canada Revenue Agency (CRA) announced far-reaching changes to the Voluntary Disclosures Program (VDP) for income tax matters that proposed to limit the relief...more

Burr & Forman

You or Your Business Gets an IRS Audit Notice: What Do You Do? Defending an IRS Audit (Part 10)

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The United States has a voluntary tax reporting system. Once a tax return is filed, however, the IRS will seek to verify that filed tax returns comply with the tax laws. To achieve this, an IRS audit (“examination”) must take...more

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