Category Archives: 214 OVDP

OFFSHORE VOLUNTARY DISCLOSURE PROGRAM (OVDP): STRICT APPLICATION OF 50% PENALTY CAN BE HARSH

Posted on February 15, 2015 by taxpenaltylawyer

Consider the following fact pattern: Father and daughter are participants in the OVDP who submitted their OVDP Letters after August 4, 2014.   Each owned separate unreported offshore bank accounts during the OVDP period 2006 through 2013. The father’s account was … Continue reading →

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IRS UNRELENTING IN PURSUIT OF UNREPORTED OFFSHORE ACCOUNTS

Posted on January 28, 2015 by taxpenaltylawyer

Today the IRS released IR-2015-9, “Hiding Money or Income Offshore Among the “Dirty Dozen” List of Tax Scams for the 2015 Filing Season” which provides verbatim: WASHINGTON — The Internal Revenue Service today said avoiding taxes by hiding money or … Continue reading →

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EVALUATING RISK OF PROSECUTION OUTSIDE OF THE OVDP

Posted on December 10, 2014 by taxpenaltylawyer

An article authored by Edward Robbins, Jr. Steven Toscher and Dennis Perez, “What’s Your Client’s Criminal Exposure on His Undeclared Foreign Bank Account? (Journal of Tax Practice, October – November 2012 pp 67-74), astutely summarizes the most likely charged tax … Continue reading →

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THERE’S NOTHING CIVIL ABOUT THE STREAMLINED FILING PROCESS

Posted on December 2, 2014 by taxpenaltylawyer

Many believe that you can bifurcate the Streamlined Process between the criminal aspect and civil aspect.  That once you have a non-willful opinion from the criminal tax lawyer, the process becomes civil and any competent civil tax lawyer or tax … Continue reading →

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SOME CLARIFICATION FROM IRS ON THE STREAMLINED FILING COMPLIANCE PROCEDURES.AND DEINQUENT INTERNATIONAL INFORMATION RETURN SUBMISSIONS.

Posted on November 9, 2014 by taxpenaltylawyer

The IRS has updated its Streamlined Filing Compliance Procedures and Delinquent International Information Return pages (October 9, 2014) and issued Frequently Asked Questions with regard to each. The FAQs for U.S. Taxpayers residing in the U.S. clarify that: The 5% … Continue reading →

Posted in 214 OVDP, COMPLIANCE, FBARS, OFFSHORE BANK ACCOUNTS, TAX | Tagged , , , , , , , , | 1 Comment

PRO SE TAXPAYERS OFTEN DON’T SEE THE BUS THAT HITS THEM: SELF-REPRESENTATION CAN BE DANGEROUS

Posted on October 6, 2014 by taxpenaltylawyer

I receive many calls from taxpayers considering how to bring their unreported offshore accounts into compliance. Sometimes and often with respect to expatriates, these individuals will have prepared their own returns and even attempted to represent themselves through some of … Continue reading →

Posted in 214 OVDP, DIVORCE, EQUITABLE RELIEF, INNOCENT SPOUSE, NEW OVDP, TAX | Tagged , , , , | 1 Comment

BLOOMBERG BNA SAMPLES ATTORNEY VIEWS ON STREAMLINED PROCESS

Posted on September 20, 2014 by taxpenaltylawyer

Alison Bennett of Bloomberg BNA’s article “Questions surround Standard of Willful Path Conduct under Streamlined Version of OVDP” (9/17/14), summarizes some of her interviews with tax lawyers around the country concerning the Streamlined Filing Compliance Procedures announced by IRS on … Continue reading →

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WHAT SHOULD YOU DO? YOU FAILED TO FILE AN FBAR BUT REPORTED ALL INCOME FROM AN OFFSHORE ACCOUNT

Posted on July 24, 2014 by taxpenaltylawyer

This predicament is not an uncommon occurrence.  Many taxpayers may have had a foreign bank or brokerage account and reported the income in their tax returns or earned no income but did not know they had to file an FBAR.  … Continue reading →

Posted in 214 OVDP, FBARS, NEW OVDP, OFFSHORE BANK ACCOUNTS, STATUTE OF LIMITATIONS, TAX | Tagged , , , , , , | 42 Comments

SOME SWISS BANKS ARE MORE THAN ENCOURAGING U.S. CLIENTS TO ENTER THE OVDP – THEY ARE OFFERING FINANCIAL INCENTIVES

Posted on July 21, 2014 by taxpenaltylawyer

An article in the Wall Street Journal on July 19, 2014 by John Letzing (“Taxpayers Get Incentives to Report: Swiss Banks Aim to Entice Americans to Disclose Accounts to IRS by Helping Cover Costs, Penalties”), reveals what many professionals have … Continue reading →

Posted in 2012 OVDP, 214 OVDP, FBARS, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX, TAX CRIMES, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , , , , , | 1 Comment

THE TAX LAW IS COMPLEX; OFFSHORE COMPLIANCE DECISIONS ARE DIFFICULT AND MISTAKES CAN HAVE GRAVE CONSEQUENCES

Posted on July 18, 2014 by taxpenaltylawyer

John J. Scroggin published an interesting and entertaining survey of tax complexity in the Wealth Strategies Journal (Tax Complexity, History, and Humor, July 8, 2014). The article begins with a quote from Judge Learned Hand:  “In my own case the … Continue reading →

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