News & Analysis as of

OVDP

Update on IRS Offshore Initiatives

by Moskowitz LLP on

Global tax issues are a top priority for the Internal Revenue Service Criminal Investigation Division (IRS-CI), which focuses its work on investigating taxpayers who willfully engage in tax evasion. Significant efforts are...more

Why are US Citizens Renouncing their Citizenship?

by Foodman CPAs & Advisors on

A significant number of US Taxpayers living overseas have become “unbankable” where they live because of high account servicing costs for local banks (Foreign Financial Institutions – also known as FFIs) caused by the...more

More Data Added To Paradise Papers Offshore Leaks Database

by Fox Rothschild LLP on

Yesterday the International Consortium of Investigative Journalists released information from the corporate registries of four more tax havens that were included in the Paradise Papers investigation: Barbados, the Bahamas,...more

US prosecutors seek tenfold increase in offshore evasion sentences

by Sanford Millar on

A conviction for failure to report offshore financial account now carries a far greater risk of a lengthy prison term according to Mark Daly, senior litigation counsel at the U.S. Department of Justice. US prosecutors seek...more

Paradise Papers, Panama Papers…. The Message is Clear: Report Offshore Accounts!

by Foodman CPAs & Advisors on

First, the Panama Papers, and now… the Paradise Papers. The Paradise Papers contain the names of approximately 31,000 US citizens, including entities, or persons with US addresses....more

What If You Are Ineligible For The Offshore Voluntary Disclosure Program? Attorney Proffers versus Quiet Disclosures

by Sanford Millar on

Since the beginning of the current Offshore Voluntary Disclosure Programs (OVDP) in 2009 tens of thousands of U.S. taxpayers have come forward to report previously undisclosed foreign financial accounts. The addition of the...more

On Eve Of “Paradise Papers” Release, At-Risk Individuals Should Consider Immediate Action To Mitigate Potential For Criminal...

by Fox Rothschild LLP on

Tomorrow morning (November 17) the International Consortium of Investigative Journalists (ICIJ) is set to release publicly the first set of comprehensive data from the recent “Paradise Papers” leak. The initial data will...more

Avoiding the “Automatic” $10,000 Penalty for Late Filing of International Information Returns

by Sanford Millar on

Taxpayers who fail to timely file international information returns, such as Form 3520, Annual Return of a Controlled Foreign Corporation are subject to an automatic assessment of $10,000 per return per year up to a maximum...more

Offshore Assets May Be Subject to Enforced Collection by the IRS

by Sanford Millar on

The fact that you may have assets offshore does not mean that they are immune from seizure by the IRS. A recent case illustrates how the IRS can enforce collection outside the United States....more

Undisclosed Foreign Accounts, Part II

by Moskowitz LLP on

The executor of a decedent’s estate has a duty to act in a prudent manner and in accordance with the law. At times, this may result in having to take an unpopular position or action that angers the beneficiaries....more

The Manafort Indictment and what it means to you.

by Sanford Millar on

On October 30, 2017 Paul Manafort, the former campaign chair for president Donald Trump was indicted by a Federal Grand Jury in the District of Columbia. The charges arise from Manafort's unregistered consulting and...more

Are you a Taxpayer identified by IRS for not Reporting Offshore Financial Assets?

by Foodman CPAs & Advisors on

Taxpayers with unreported foreign financial assets and income run the risk of having the Government determine if their conduct was willful or non-willful. The definition of “Willful" or "non-willful” in Taxpayer’s conduct...more

Do Not Expect Anonymity from Virtual Currency

by Sanford Millar on

There is a widely held misconception that using virtual currency such as BitCoin assure the users that their transaction is anonymous. For this reason virtual currency is used to move money from countries with currency...more

Overview of IRS Penalties for Individuals with Foreign Bank Accounts and Investments

by Blank Rome LLP on

Earlier this spring, the Internal Revenue Service ("IRS") Large Business and International Division identified several "campaigns" or areas where it plans to focus its audit resources. One campaign involved taxpayers who...more

Why you need EXPERT ADVICE if you have a PFIC and you are out of Compliance!

by Foodman CPAs & Advisors on

Taxpayers need to rely on the expert professional advice of a tax specialist for the treatment of Passive Foreign Investment Companies (PFICs) during Offshore Voluntary Disclosure Program (OVDP) reporting. PFIC computations...more

FBAR Penalty Amounts are in the “Best Judgement” of an IRS Examiner

by Foodman CPAs & Advisors on

The Report of Foreign Bank and Financial Accounts (FBAR) is not a tax form. Its filing is not required by the Internal Revenue Code. It is required by Title 31 of the Code of Federal Regulations. Title 31 is the Bank Secrecy...more

2017 OVDP Declines and Withdrawals Campaign: Certain U.S. Taxpayers at Risk of Audit

In 2016, the Treasury Inspector General for Tax Administration (TIGTA) released a report which assessed how well that IRS was managing the Offshore Voluntary Disclosure Program (OVDP). OVDP is one of the programs taxpayers...more

ICAP: It's Not a TRAP

by Alston & Bird on

An IRS official recently stated that the United States will participate this fall along with several other countries in a pilot of the “international compliance assurance program (ICAP). ICAP is a “tax risk assessment...more

IRS Announces Tax Audit Targets

Over the past several years, IRS has reduced the number of its tax auditors by about 25 percent – from just over 12,000 tax auditors in 2011 to about 9,000 tax auditors in 2015. This staffing reduction has forced IRS to focus...more

Applying Overpayments of Tax to Tax and the Offshore Penalty in the OVDP Program

by Charles (Chuck) Rubin on

The OVDP program allows taxpayers to remedy deficient disclosure filings relating to offshore accounts for a fixed penalty amount. As part of the program, taxpayers must file either original or amended tax returns which...more

Developing a Strategy to Fight FBAR Penalties

by Carlton Fields on

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

Choose Opt Out Option Wisely in Offshore Voluntary Disclosure Program

Since 2009, the Internal Revenue Service has offered a variety of offshore voluntary disclosure programs (collectively, OVDP) under which a U.S. taxpayer can disclose previously undisclosed offshore activities. However, these...more

IRS Agent Discusses the Look-Back Period for Filing Delinquent International Information Returns

We represent a client who may need to file delinquent international information returns under the IRS Delinquent International Information Return Submission Procedures. These procedures invite taxpayers who meet the...more

Getting Into Compliance with Your Foreign Account Reporting, Part II

by Moskowitz LLP on

In Part I, we listed some of the penalties associated with the failure to report foreign accounts, and what is widely regarded as the best option for coming into compliance – the Offshore Voluntary Disclosure Program (OVDP)....more

Getting Into Compliance with Your Foreign Account Reporting, Part I

by Moskowitz LLP on

With the 2015 release of the “Panama Papers,” roughly 11.5 million documents detailing personal financial information of wealthy individuals and identifying nearly 215,000 offshore entities are now available to government...more

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