Tag Archives: FBAR

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

IRS UNRELENTING IN PURSUIT OF UNREPORTED OFFSHORE ACCOUNTS

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

Posted in 214 OVDP, OFFSHORE BANK ACCOUNTS, TAX, VOLUNTARY DISCLOSURE | Tagged , , , , , , , | 1 Comment

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

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

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

Posted in 214 OVDP, FBARS, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , , , , , | Leave a comment

STILL HAVE AN UNREPORTED FORIEGN FINANCIAL ACCOUNT? BEWARE THE TRUSTED ADVISORS: THEY WILL GIVE YOU UP TO SAVE THEIR OWN SKINS

The DOJ Press Release reproduced below in its entirety should be very scary to those still out in the cold with unreported foreign financial accounts.  We know that foreign banks are taking steps to minimize their risk of criminal prosecution … Continue reading

Posted in 2012 OVDP, 214 OVDP, FBARS, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX CRIMES, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , , , , , , | 2 Comments

SOME ADVANTAGES AND DISADVANTAGES OF STREAMLINED PROCEDURES FOR U.S. CITIZENS AND RESIDENTS RESIDING IN THE U.S.

“Beware of false knowledge; it is more dangerous than ignorance.” – George Bernard Shaw Shaw’s admonition is applicable to the recently announced Streamlined Process and Transitional as alternatives for resolving offshore noncompliance exposure of U.S. citizens and residents.  Calls I’ve … Continue reading

Posted in 2012 OVDP, 214 OVDP, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX, TAX CRIMES | Tagged , , , , , , , , , , , , , | Leave a comment

INITIAL THOUGHTS ON IRS CHANGES TO OFFSHORE VOLUNTARY DISCLOSURE PROGRAM AND STREAMLINED PROCESS FOR NON-WILLFUL TAXPAYERS

Yesterday, June 18, 2014, IRS announced and posted to the Offshore Voluntary Disclosure page on its website (www.irs.gov) significant changes to the 2012 OVDP reflected in revised Frequently Asked Questions; and, new Streamlined Filing Compliance Procedures for non-willful, out-of-compliance taxpayers, whether … Continue reading

Posted in 2012 OVDP, COMPLIANCE, FBARS, NEW OVDP, TAX, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , , , , , | 11 Comments