Tag Archives: OVDP OPT OUT

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

Posted on July 18, 2014 by steinbergtaxlaw

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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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

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

Posted on June 19, 2014 by steinbergtaxlaw

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

ACCIDENTAL U.S. TAX RESIDENTS CAUGHT IN OFFSHORE DISCLOSURE WEB

Posted on November 15, 2013 by steinbergtaxlaw

One of the difficult aspects of U.S. tax law for foreign persons to understand is how they become accidental U.S. tax residents.  Even those here without a Green Card on non-immigration visas, can be required in any given year to … Continue reading →

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

MORE STORM CLOUDS FOR HIDDEN OFFSHORE ACCOUNTS

Posted on November 1, 2013 by steinbergtaxlaw

The holes in which to hide for offshore tax cheats are steadily being filled up.  Those who have not entered the IRS Offshore Voluntary Disclosure Program, will find no comfort in some recent news, namely: Bank Frey, the “Truly Swiss, … Continue reading →

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OVDP OR NOTHING AT ALL

Posted on July 14, 2013 by steinbergtaxlaw

The 1939 song, “All or Nothing at All,” (by Arthur Altman and Jack Lawrence) made popular by Frank Sinatra might be sung in a new version by IRS, “OVDP or Nothing at All.” The Bank Secrecy Act contains draconian penalties … Continue reading →

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OFFSHORE VOLUNTARY DISCLOSURE UPDATE – JANUARY 2013

Posted on February 1, 2013 by steinbergtaxlaw

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 →

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