Tag Archives: OVDP

BLOOMBERG BNA SAMPLES ATTORNEY VIEWS ON STREAMLINED PROCESS

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

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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

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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

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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

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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

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RESIDENCE OF PARTICIPANTS IN 2009 OVDP AND FOREIGN COUNTRIES IN WHICH DISCLOSED FINACIAL ACCOUNTS WERE LOCATED

On January 6, 2014 the U.S. Government Account Office (GAO) reported to Senator Carl Levin, Chairman, Permanent Subcommittee on Investigations, Committee on Homeland Security and Governmental Affairs, certain information about the participants in the 2009 IRS Offshore Voluntary Disclosure Program … Continue reading

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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

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