Tag Archives: NON-WILLFUL

TAXPAYERS MUST BECOME COMPLIANT WITH U.S. OFFSHORE TAX FILING REQUIREMENTS AND FBAR REPORTING BY 2016 – TIME MAY BE RUNNING OUT ON NON-WILLFULNESS CLAIMS

Posted on November 17, 2016 by taxpenaltylawyer

For some time now, I’ve been receiving frequent calls from U.S. citizens or Green Card holders living outside of the U.S. and U.S. citizens, Green Card holders and residents living in the U.S. who have been out of compliance with … Continue reading →

Posted in 2014 OVDP, STREAMLINED FILING COMPLIANCE PROCEDURES, STREAMLINED FILINGS, Uncategorized | Tagged , , , | Leave a comment

IRS COMMENTS ON NEW STREAMLINED FILING PROCEDURES FOR NON-WILLFUL OFFSHORE TAXPAYERS

Posted on June 21, 2014 by taxpenaltylawyer

 Amy S. Elliott’s article, IRS Answers Questions on Updated OVDP and Streamlined Filing, 2014 TNT 120-9 (6/23/14) summarizes selected comments of IRS officials at NYU’s recent Tax Controversy Forum. Two IRS officials were present: Jennifer Best, senior adviser, IRS Large … Continue reading →

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

OFFSHORE VOLUNTARY DISCLOSURE UPDATE – JANUARY 2013

Posted on February 1, 2013 by taxpenaltylawyer

LEVEL OF PARTICIPATION IN PROGRAMS On June 26, 2012 the IRS had released IR-2012-64, which stated:  Shulman (IRS Commissioner Doug Shulman) said the IRS offshore voluntary disclosure programs have so far resulted in the collection of more than $5 billion … Continue reading →

Posted in 2012 OVDP, AUDITS, FBARS, NEW OVDP, TAX, TAX CRIMES, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , | Leave a comment