Category Archives: STREAMLINED FILING COMPLIANCE PROCEDURES

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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NONWILFUL AFFIDAVITS UNDER THE STREAMLINED FILING COMPLIANCE PROCEDURES

Normally, the tax-rules that taxpayers must follow are contained in the Internal Revenue, Code, Treasury Regulations promulgated by the IRS, Revenue Rulings issued by the IRS and court cases. For taxpayers seeking to enter either the IRS’ formal criminal amnesty … Continue reading

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OWE TAXES? NO PASSPORT! IRS MAY SCUTTLE TRAVEL PLANS OF THOSE WHO DON’T PAY UP

Congress has a sneaky habit of attaching tax bills to end-of-the-year highway funding legislation. HR22, the Surface Transportation Reauthorization and Reform Act of 2015,” has tucked into Title 52 a nasty little tax ditty that creates new Internal Revenue Code … Continue reading

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STATUTES OF LIMITATIONS AND STREAMLINED FILINGS OR FILE FORWARD STRATEGIES

In earlier blog posts I have discussed how Streamlined Filings differ from OVDP submissions. One major difference: unlike an OVDP submission, a taxpayer making a Streamlined Filing is not informed upfront whether his or her filing has been accepted as … Continue reading

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IRS ADDS TWO MORE BAD BANKS TO ITS 50% LIST AND ISSUES FBAR PENALTY GUIDELINES

Bad Banks subject account holders to 50% penalty On June 3, 2015 the IRS added two more banks to its list of banks at which accounts subject the holder to a 50% OVDP miscellaneous offshore penalty on all offshore assets … 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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STREAMLINED NON-WILLFUL CERTIFICATIONS: DON’T LIE, DON’T’ EXAGGERATE AND DON’T CHERRY-PICK YOUR FACTS

The Department of Justice Tax Division acting assistant attorney general, Caroline Ciraolo, speaking at the Federal Bar Association Tax Section annual tax conference (reported by Nathan J. Richman, Tax Analysts Tax Notes Today, March 9, 2015), stated: We are taking … Continue reading

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