Category Archives: STREAMLINED FILING COMPLIANCE PROCEDURES

STREAMIINED FILING COMPLIANCE PROCEDURES FREQUENTLY ASKED QUESTIONS ADDRESS ONE CONCERN AND CREATE ANOTHER

The IRS occasionally posts updates to its Frequently Asked Questions for the Streamlined Filing Compliance Procedures, both for taxpayers residing in and outside of the United States. The last update of the FAQs was made by IRS on July 18, … Continue reading

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THE DANGER OF RELYING ON MEMORY IN STREAMLINED NONWILLFUL CERTIFICATIONS

A Wall Street Journal article of July 27, 2016, “How Inaccurate Memories Can Be Good for You,” by Sue Shelenbarger, discusses a number of studies that found benefits to people from even inaccurate memories. More important that accuracy is that … Continue reading

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MORE ON INHERENT RISK IN STREAMLINED NON-WILLFUL CERTIFICATIONS

I have posted often about the risk of using the Streamlined Filing Compliance Procedures, specifically about the risk of making a statement under penalties of perjury of the reasons the taxpayer believes his or her conduct in failing to comply … Continue reading

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COMPARISON CHART – OVDP VS. STREAMLINED FILING COMPLIANCE PROCEDURES

COMPARISON CHART – OVDP VERSUS STREAMLINED © 2016 by Robert S. Steinberg, Esquire. All rights reserved http://www.steinbergtaxlaw.com   CHARACTERISTIC OVDP STREAMLNED Up Front Qualification? Yes -Names clearance (30 days) & Provisional acceptance after OVDP letter (45 days) – CI reviews … Continue reading

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WAITING IS A DANGEROUS GAME FOR THOSE STILL NOT IN COMPLIANCE WITH FOREIGN REPORTING RULES

Over 55,000 taxpayers have come into compliance by entering the Offshore Voluntary Disclosure Program. An untold number of less culpable non-willful taxpayers have come into compliance under the Streamlined Filing Compliance Procedures.  Some with reasonable cause have used the delinquent … Continue reading

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OFFSHORE NONCOMPLIANCE: THE NIGHTMARE THAT MORNING DOES NOT END

From every bad dream there is an awakening. Morning brings you back to sanguinity.For those with offshore activities who are out of compliance with U.S. tax law, however,  morning will not come unless and until they undertake some course of … Continue reading

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FOR WHOM THE BELL TOLLS ON STREAMLINED FILINGS

A Tax Analysts Tax Notes article (Richman, Nathan J., “International Tax Enforcement Efforts Include Civil Tools”) quoted Acting Assistant Attorney General of the Department of Justice Tax Division, Caroline Ciraolo who was speaking at the March 4th Federal Bar Association … Continue reading

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