Tag Archives: OVDP BENEFITS

EVALUATING RISK OF PROSECUTION OUTSIDE OF THE OVDP

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

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

WHY NOW IS A PROPITIOUS TIME FOR THOSE WITH UNREPORTED OFFSHORE ACCOUNTS TO MAKE A VOLUNTARY DISCLOSURE?

One oddity about the Offshore Voluntary Disclosure Program (OVDP) is that the FBAR years included in the criminal and reduced penalty partial-amnesty period are geared to one’s income tax filings.  (IRS OVDP FAQ 9) Thus, once a correct income tax … Continue reading

Posted in 2012 OVDP, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX, TAX INFORMATION EXCHANGE AGREEMENTS, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , , , , , , , , , , | Leave a comment

LATEST DOJ ATTACK ON OFFSHORE ACCOUNTS: JOHN DOE SUMMONSES ISSUED TO U.S. CORRESPONDENT BANKS OF OFFSHORE BANKS

By now, I’m sure anyone owning an undisclosed offshore bank account has become familiar with the term, “John Doe Summons.”  After all, following the IRS issuing a John Doe Summons to UBS, it announced the 2009 OVDP, and about 15,000 … Continue reading

Posted in 2012 OVDP, FBARS, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , , , , , , , , , , | Leave a comment