Tag Archives: NEW STREAMLINED PROCESS FOR OFFSHORE ACCOUNTS

IRS OFFICIALS ANSWER CIVIL AND CRIMINAL OFFSHORE QUESTIONS

Posted on February 26, 2015 by steinbergtaxlaw

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

MORE FROM IRS ON NON-WILLFULNESS CERTIFICATION UNDER STREAMLINED PROCESS

Posted on February 7, 2015 by steinbergtaxlaw

New IRS Form for Certification The IRS in January 2015 issued new Form 14653 (14654 for U.S. persons residing in the U.S.) which revises and replaces the required Certification by. U.S. Person Residing Outside of the Unites States for Streamlined … Continue reading →

Posted in STREAMLINED FILING COMPLIANCE PROCEDURES, STREAMLINED FILING COMPLIANCE PROCEDURES, TAX | Tagged , , , , , , | Leave a comment

THERE’S NOTHING CIVIL ABOUT THE STREAMLINED FILING PROCESS

Posted on December 2, 2014 by steinbergtaxlaw

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 →

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

BLOOMBERG BNA SAMPLES ATTORNEY VIEWS ON STREAMLINED PROCESS

Posted on September 20, 2014 by steinbergtaxlaw

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 →

Posted in 214 OVDP, TAX | Tagged , , , , , , , , | 1 Comment

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

Posted on June 30, 2014 by steinbergtaxlaw

“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