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Tag Archives: REASONABLE CAUSE
IRS NOOSE TIGHTENS ON THOSE WITH UNREPORTED OFFSHORE ACCOUNTS: CARIBBEAN AND AUSTRALIAN ACCOUNT HOLDERS AT GREAT RISK
The IRS continues to cast a wider net for offshore tax cheats and continues to make the cost of waiting to come into compliance expensive. Some recent developments illustrate: Tax storm in the Caribbean: The IRS had previously served a … Continue reading →
Posted in OFFSHORE BANK ACCOUNTS
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Tagged AUSTRALIA DISCLOSES US ACCOUNT HOLDERS, BELIZE BANK SUMMONS, CIBC, COMPETENT AUTHORITY AGREEMENTS UNDER FATCA IGAS, DELINQUENT FBAR SUBMISSION PROCEDURES, DELINQUENT INTERNATIONAL INFORMATION RETURN PROCEDURES, IRS STREAMLINED FILING COMPLIANCE PROCEDURES, LIST OF BAD BANKS, OVDP - 50% PENALTY, QUIET DISCLOSURES, REASONABLE CAUSE
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NON-WILLFUL FBAR PENALTY: TAXPAYER FOUND BY DISTRICT COURT TO LACK REASONABLE CAUSE FOR HAVING FAILED TO FILE FBARS. COURT ALSO RULES AGAINST TAXPAYER ON DUE PROCESS AND EXCESSIVE FINE ARGUMENTS.
After James Moore had filed amended returns and delinquent FBARS, the IRS assessed against him maximum non-willful FBAR penalties of $10,000 for each of the years 2005 through 2008, for a total of $40,000. Instead of waiting for the Treasury … Continue reading →
IRS OFFICIALS ANSWER CIVIL AND CRIMINAL OFFSHORE QUESTIONS
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
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Tagged AMENDED RETURNS, FBAR, FBAR PENALTIES, FOREIGN BANK ACCOUNTS, IRS STREAMLINED FILING COMPLIANCE PROCEDURES, NEW STREAMLINED PROCESS FOR OFFSHORE ACCOUNTS, OFFSHORE BANK ACCOUNTS, OFFSHORE TAX FRAUD, OVDP, QUIET DISCLOSURES, REASONABLE CAUSE, ROBERT S STIENBERG, SWISS BANK SETTLEMENT PROGRAM, VOLUNTARY DISCLOSURE, WILLFULNESS
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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
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Tagged 2012 OVDP, CHANGES IN OVDP PROCEDURES, FBAR, FBAR PENALTIES, FOREIGN BANK ACCOUNTS, OFFSHORE ACCOUNTS, OFFSHORE TAX FRAUD, OVDP BENEFITS, OVDP OPT OUT, QUIET DISCLOSURES, REASONABLE CAUSE, Robert S. Steinberg, STREAMLINED FILING COMPLIANCE PROCEDURES
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ACCIDENTAL U.S. TAX RESIDENTS CAUGHT IN OFFSHORE DISCLOSURE WEB
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
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Tagged # INDIVISIBLE, FBAR, FBAR PENALTIES, NON-RESIDENT ALIEN, OVDP OPT OUT, QUIET DISCLOSURES, REASONABLE CAUSE, RESIDENT ALIEN, Robert S. Steinberg, SUBSTANTIAL PRESENCE TEST, TD F 90.22-1
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OFFSHORE VOLUNTARY DISCLOSURE UPDATE – JANUARY 2013
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
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Tagged # INDIVISIBLE, 2012 OVDP, NON-WILLFUL, OFFSHORE BANK ACCOUNTS, OVDP OPT OUT, REASONABLE CAUSE, Robert S. Steinberg, UBS, VOLUNTARY DISCLOSURES
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