Tag Archives: REASONABLE CAUSE

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

Posted in 2014 OVDP, AMENDED RETURNS, FBARS | Tagged , , , , , | Leave a comment

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 | Tagged , , , , , , , , , , , , , , | 8 Comments

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

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 | Tagged , , , , , , , , , , | Leave a comment

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 | Tagged , , , , , , , , | Leave a comment