Monthly Archives: May 2015

THE CLOCK IS TICKING ON THE 27.5% OVDP OFFSHORE PENALTY (AS OPPOSED TO 50%) FOR THOSE WITH ACCOUNTS AT BANKS SOON TO BE ADDED TO THE IRS BAD BANKS LIST

The Department of Justice (DOJ) on May 29, 2015 announced that four more Swiss banks had entered into non-prosecution agreements (NPA), namely: Societe Generale Private Banking (Lugano-Svizzera) SA (effective 5/28/15) MediBank AG (effective 5/28/15) LBBW (Schweiz) AG (effective 5/28/15) Scobag … Continue reading

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OVDP – LIST OF BANKS AT WHICH AN ACCOUNT UPS OFFSHORE PENALTY TO 50% IS GROWING

The IRS continues to add to its published list of banks at which an account, even one account, increases the Miscellaneous Offshore Penalty imposed as part of the OVDP from 27.5% to 50% on all offshore assets connected with the … Continue reading

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STREAMLINED FILING COMPLIANCE PROCEDURES: IRS ROADBLOCKS

The IRS announced with great fanfare its 2014 updated version of the Streamlined Filing Compliance Procedures.  These simplified filing procedures were touted as a filing process under which U.S. noncompliant taxpayers living in the U.S. or outside the U.S. could … Continue reading

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NON-WILLFUL FBAR PENALTY: TAXPAYER FOUND BY DISTRICT COURT TO LACK REASONABLE CAUSE FOR HAVING FAILED TO FILE FBARS. COURT ALSO RULES AGAINST TAXPAYER ON DUE PROCESS AND EXCESSIVE FINE ARGUMENTS.

After James Moore had filed amended returns and delinquent FBARS, the IRS assessed against him maximum non-willful FBAR penalties of $10,000 for each of the years 2005 through 2008, for a total of $40,000.  Instead of waiting for the Treasury … Continue reading

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