Example of the Penalty Structure in the OVDP Process
The Criminal Investigative unit is charged with assessing the penalty structure. The structure itself is nonnegotiable and the examiner l… Read More
LOS ANGELES, April 04, 2016 (GLOBE NEWSWIRE) — Last week after nearly a year of waiting, the Brager Tax Law Group received IRS documents after filing a Freedom of Information Act (FOIA… Read More
This is a guest post by Chicago attorney Dan Janich. A little off the normal topic path for this blog, but Dan’s insights are worth sharing. This post is timely with the recent Panama… Read More
If you had foreign accounts in 2015 that in the aggregate topped $10,000 at any timeduring the year, you should file an FBAR–also called Form 114. June 30, 2016 is the filing dead… Read More
The Internal Revenue Service is missing out on imposing approximately $21.6 million in penalties on taxpayers who are denied entry or withdraw from its Offshore Voluntary Disclosure Program… Read More
I worked in India for 8 years before I moved to the land of Motherhood and Apple Pie. These were my money-is-too-boring-to-think-about spendy years, and left to my own devices I would have s… Read More
IRS Releases 2016 Offshore Voluntary Compliance Statistics On October 21, 2016 the IRS released the latest statistics on Taxpayers who have made disclosures under the Offshore Voluntary Disc… Read More
A husband and wife had an accounting in Switzerland at UBS AG, into which they deposited commissions from camera sales and also directed some of their international customers to make deposit… Read More
Accountants and tax return preparers aren’t the only busy ones during tax return filing season. Scammers and abusers of the system are active as well. The Internal Revenue Service (IRS… Read More
I wrote about the Bohanec case here in December 2016. Hale E. Sheppard recently published an article analyzing this case, along with the other 3 key cases and other authority dealing with wi… Read More
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… Read More
What Is the Offshore Voluntary Disclosure Program? The Offshore Voluntary Disclosure Program (OVDP) is an IRS program to help lessen penalties for US taxpayers who knowingly did not report f… Read More
For Canadians foreign nationals residing in the U.S. and U.S. expatriates living in Canada, taxation of Canadian investments in the U.S. can be complicated. It can even be difficult to find… Read More
5 Things You Should do if You have Unreported Foreign Income
Learn about what to do if you have unreported foreign income and accounts. Non-Compliance with foreign asset reporting can lead t… Read More
Is Quiet Disclosure Ever a Good Option?
What is a Quiet Disclosure?
In the world of offshore voluntary compliance, a quiet disclosure refers to filing amended returns and paying an… Read More
Offshore Tax Compliance for Investments in India
FATCA INDIA
For US residents with investments in India, compliance with FATCA and the US tax code can be burdensome. We’ll discuss… Read More
FBAR Civil Penalties – A Case Study
Here is a recently filed complaint where the Government is seeking to collect civil FBAR penalties assessed under 31 U.S.C. § 5321(a)… Read More
IRS Tax Amnesty & Voluntary Disclosure Practice
What do you do if you have committed a serious tax crime but the IRS has not yet discovered it? Tax amnesty has been a longstanding practi… Read More
The Internal Revenue Service (IRS) has announced that Offshore Voluntary Disclosure Program (OVDP) is coming to a close. The program, which has been around in its current form since 2014, wi… Read More
The IRS has announced that on September 28th, 2018, it is closing its Offshore Voluntary Disclosure Program (OVDP).
Background
The IRS created a series of OVDP programs that began in 2009. O… Read More
Internal Revenue Service plans to close the Offshore Voluntary Disclosure Program (OVDP) on September 18, 2018. The Internal Revenue Service recently announced that they will be winding… Read More
The OVDP commenced in 2009, and provided a mechanism for U.S. taxpayers who had not complied with various non-U.S. information disclosure and tax payments to square up with the IRS without r… Read More
The Internal Revenue Service (IRS) recently announced that the Offshore Voluntary Disclosure Program (OVDP) will officially end on September 28, 2018.
Acting IRS Commissioner David Kautter… Read More
DEFINITION of ‘Amnesty’
Amnesty is pardon granted by an authority, such as a government, to a group or class of people as a whole. While “amnesty” is generally grant… Read More
Profit Utilization of Limited Liability Company in Indonesia
A Potential Regulatory Regime for Virtual Currencies is Proposed by EBA
FATCA – Malta on the Way to Implementing its IGA… Read More
IRS Streamlined Foreign Offshore Procedures
The streamlined foreign offshore procedures (SFOP) are one of the two programs available in the streamlined filing compliance procedures. It is av… Read More
What to do after the Offshore Voluntary Disclosure Program ends?
Earlier this year the IRS announced that it would be ending the offshore voluntary disclosure program on September 28, 2… Read More
Court Says FBAR Willful Penalty not Limited to $100,000
Breaking from Wadhan and Colliot, the court in Norman v. United States, No. 15-872T (Ct. Cl. 2018) recently held that FBAR w… Read More
IRS Reminds Taxpayers of OVDP Ending and Hints at Updated Procedures
Earlier this year the IRS announced that the OVDP would end on September 28th and the IRS issued a reminder to taxpayers… Read More
The clock continues to tick down for taxpayers hoping to take advantage of the Offshore Voluntary Disclosure Program (OVDP). The Internal Revenue Service (IRS) will close the program on Sept… Read More
As of September 28, 2018, the Internal Revenue Service (IRS) is ending the Offshore Voluntary Disclosure Program (OVDP). By law, all US citizens and residents are required to report foreign… Read More
IRS Evaluates Crytocurrency Taxable Events
At a recent conference, the IRS opened up about its cryptocurrency compliance efforts.
To combat tax evasion from those engaged in cryto trading, t… Read More
Nuong Faalong is a broadcast journalist and a writer.Today on Ghana Rising we are shifting attention from the banking crisis to explore Ghana’s Tax Amnesty Period.
The subject is perti… Read More
IRS Adds FATCA as a Compliance Campaign
Each year the IRS rolls out campaigns to identify the the top compliance issues for the year. For each of these campaigns, the IRS will deploy resourc… Read More
IRS Updates Voluntary Disclosure Practice
The IRS issued a memorandum on November 29, 2018 that updates the process for domestic and offshore voluntary disclosures after the 2014 offshore vo… Read More
Hear, Hear, Offshore Account Holders! The IRS Is Coming For You!
If you hold an offshore account, you must be aware of the strict watch that the IRS keeps on you. And until now, offshore ac… Read More
Termination of OVDP and way forward Following the termination of the Offshore Voluntary Disclosure Program (OVDP) on September 28, 2018, willfully delinquent taxpayers with exposure to… Read More
It’s already understood that the failure to disclose foreign accounts can result in significant penalties. Yet while offshore enforcement concerning foreign accounts was significantly… Read More
The timeline is closer to where American citizens can no longer apply for relief under the Offshore Disclosure Program (OVDP). The OVDP, which has been running for 10 years, is due to shut d… Read More
On behalf of Silver Tax Group posted in Offshore Accounts on Thursday, March 22, 2018.
The IRS plans on bringing to a close the Offshore Voluntary Disclosure Program (… Read More
When you’re a Cannabis entrepreneur, it may be tempting to DIY your business finances to help improve the bottom line. However, many people underestimate the critical importance of tra… Read More
Can FBAR penalties be assesed on a per account basis? In the recent United States v. Boyd, the court answered that question when it found that non-willful FBAR penalties can be assessed on a… Read More
When you as a Michigan resident have combined balances of foreign accounts exceed $10,000, you will need to file a disclosure statement with tax authorities. Failure to do so could result in… Read More
On behalf of Silver Tax Group posted in Offshore Accounts on Thursday, March 30, 2017.
The Internal Revenue Service will likely continue to crackdown on alleged failur… Read More
On behalf of Silver Tax Group posted in Offshore Accounts on Thursday, November 3, 2016.
Recent actions document IRS efforts to target offshore revenues. It appea… Read More
Those with assets in foreign bank accounts of over $10,000 are required to file the proper documentation with the IRS, including a Report of Foreign Bank and Financial Accounts(FBAR). F… Read More
In United States v. Horowitz, an OVDI/OVDP “opt out” case, the Taxpayer appeals a summary judgment decision involving FBAR willfulness penalties.
Facts
Taxpayers are married U.S… Read More
From the DOJ press release.
A federal grand jury returned a superseding indictment charging Brian Booker, a former resident of Fort Lauderdale, Florida, whose business specialized in interna… Read More
If you have undisclosed foreign accounts, perhaps the only thing worse than not coming forward voluntarily is submitting an incomplete disclosure. In United States v. Vinci, No. 8:19-cv-0244… Read More
In U.S. v. Tonisson, No. 3:19-cv-01497, the government filed a complaint to reduce to judgment almost $100,000 in FBAR penalties for Taxpayer’s non-willful failure to report foreign ba… Read More
Lake Worth Businessman Dusko Bruer Pleads Guilty To Evading Taxes On Millions In Income, Stashing Funds In Secret Accounts Around The World
(STL.News) – A Lake Worth, Florida, business… Read More
The IRS requires Americans to report foreign financial accounts — including bank accounts, mutual funds, and brokerage accounts — to the Treasury Department, in additio… Read More
If you are among the growing number of Americans who generates income through overseas businesses or properties, you likely take a variety of measures to protect your offshore assets. T… Read More
US tax laws are complicated enough. Throw international tax law into the mix and it’s double the confusion. Fear of unknown tax implications keep thousands of otherwise upstanding and… Read More
If a taxpayer doesn’t disclose any offshore accounts or pay taxes on them, they may be penalized by the IRS. In cases where the IRS determines that a taxpayer acted with willful conduc… Read More
Millions of expats pick up their lives and migrate across the world with the dream of never returning home to their country. While embracing the new culture, responsibilities, and diversifie… Read More
Understanding FBAR penalties is crucial for Americans living overseas with foreign financial accounts.
Non-compliance with FBAR regulations can incur severe consequences, including both fina… Read More
The IRS Voluntary Disclosure Program is a crucial tool for taxpayers.
This program, introduced in 2009, allows individuals to disclose previously undisclosed offshore accounts and assets… Read More