Category Archives: STREAMLINED FILING COMPLIANCE PROCEDURES

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

Posted in COMPLIANCE, PASSPORTS AND TAX DEBTS, STREAMLINED FILING COMPLIANCE PROCEDURES, Uncategorized | Tagged , , , , | Leave a comment

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

Posted in 2014 OVDP, FBARS, STREAMLINED FILING COMPLIANCE PROCEDURES, TAX STATUTES OF LIMITATIONS | Tagged , , , , , , , | Leave a comment

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

Posted in OFFSHORE VOLUNTARY DISCLOSURE PROGRAM, STREAMLINED FILING COMPLIANCE PROCEDURES, TAX CRIME STATUTE OF LIMITATIONS | Tagged , , , , , , , | Leave a comment

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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IRS OFFICIALS ANSWER CIVIL AND CRIMINAL OFFSHORE QUESTIONS

On February 24, 2015 I participated in an ABA Tax Section Webinar, “Answering Your Criminal and Civil Offshore Disclosure Questions.”  On the Webinar panel were two IRS officials:  David W. Horton, Director, IRS International Individual Compliance; and John C. McDougal, … Continue reading

Posted in 2014 OVDP, DELINQUENT RETURN, FBARS, NEW OVDP, OFFSHORE BANK ACCOUNTS, STREAMLINED FILING COMPLIANCE PROCEDURES, STREAMLINED FILING COMPLIANCE PROCEDURES, TAX, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , , , , , , , | 8 Comments