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Tag Archives: VOLUNTARY DISCLOSURE
OVDP TO END ON SEPT. 28, 2018 – ACT NOW ON UNDISCLOSED OFFSHORE ACCOUNTS
I don’t often post verbatim complete IRS pronouncements. This post is an exception, however, because the IRS Newswire Issue reprinted below contains an urgent message for those with unreported offshore income and / or foreign financial accounts who have not … Continue reading →
DEPARTMENT OF JUSTICE AND IRS CONTINUE TO FOCUS ON CATCHING OFFSHORE TAX CHEATS
The Department of Justice Tax Division on August 17 released a transcript of comments made by Principal Deputy Assistant Attorney General, Caroline D. Ciraolo, who had spoken at the Panama Bankers Association Anti-Money-Laundering Conference.in Panama City, Panama. Some take-aways from … Continue reading →
Posted in 2014 OVDP, STREAMLINED FILING COMPLIANCE PROCEDURES, Uncategorized
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Tagged DIVORCE AGREEMENT TAX CLAUSE, DOJ AND OFFSHORE NON-OCMPLIANCE, FBARS, IRS STREAMLINED FILING COMPLIANCE PROCEDURES, OFFSHORE ACCOUNTS, OFFSHORE TAX FRAUD, OVDP, SWISS BANK SETTLEMENT PROGRAM, SWISS BANKS, VOLUNTARY DISCLOSURE
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MORE ON INHERENT RISK IN STREAMLINED NON-WILLFUL CERTIFICATIONS
I have posted often about the risk of using the Streamlined Filing Compliance Procedures, specifically about the risk of making a statement under penalties of perjury of the reasons the taxpayer believes his or her conduct in failing to comply … Continue reading →
WAITING IS A DANGEROUS GAME FOR THOSE STILL NOT IN COMPLIANCE WITH FOREIGN REPORTING RULES
Over 55,000 taxpayers have come into compliance by entering the Offshore Voluntary Disclosure Program. An untold number of less culpable non-willful taxpayers have come into compliance under the Streamlined Filing Compliance Procedures. Some with reasonable cause have used the delinquent … 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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IRS UNRELENTING IN PURSUIT OF UNREPORTED OFFSHORE ACCOUNTS
Today the IRS released IR-2015-9, “Hiding Money or Income Offshore Among the “Dirty Dozen” List of Tax Scams for the 2015 Filing Season” which provides verbatim: WASHINGTON — The Internal Revenue Service today said avoiding taxes by hiding money or … Continue reading →
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
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Tagged BANK SECRECY ACT, FBAR PENALTIES, FOREIGN BANK ACCOUNTS, IRS STREAMLINED FILING COMPLIANCE PROCEDURES, OVDP, OVDP BENEFITS, QUIET DISCLOSURES, RISK OF PROSECUTION IN OFFSHORE CASE, ROBERT S STIENBERG, TAX CRIMES, VOLUNTARY DISCLOSURE, WILLFULNESS
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WILL-O -THE WISP NON-WILLFULNESS IN THE STREAMLINED FILING COMPLIANCE PROCEDURE
“A will-o’-the-wisp is an atmospheric ghost-light seen… at night, especially over bogs, swamps or marshes. It resembles a flickering lamp and is said to recede if approached, drawing (sojourners) from the safe paths.”(Wilkipedia). Most clients with unreported offshore accounts who … Continue reading →
Posted in TAX
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Tagged BANK SECRECY ACT, CERTIFICATION OF NON-WILLFULNESS, FBAR PENALTIES, FBAR QUESTION ON SCHEDULE B, FBARS, FOREIGN BANK ACCOUNTS, IRS STREAMLINED FILING COMPLIANCE PROCEDURES, MCBRIDE CASE, NONWILLFULNESS, OFFSHORE ACCOUNTS, OFFSHORE BANK ACCOUNTS, OFFSHORE TAX FRAUD, ROBERT S STIENBERG, VOLUNTARY DISCLOSURE, WILLFULNESS, WILLIAMS CASE
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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 →
Posted in 2012 OVDP, 214 OVDP, FBARS, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX, TAX CRIMES, VOLUNTARY DISCLOSURE
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Tagged 2012 OVDP, BANK SECRECY ACT, FBAR, FBAR PENALTIES, FOREIGN BANK ACCOUNTS, OFFSHORE ACCOUNTS, OFFSHORE TAX FRAUD, OVDP, ROBERT S STIENBERG, SWISS BANK FINANCIAL INCENTIVES, SWISS BANK SETTLEMENT PROGRAM, TAX CRIMES, VOLUNTARY DISCLOSURE
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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 →
Posted in 2012 OVDP, 214 OVDP, FBARS, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX CRIMES, VOLUNTARY DISCLOSURE
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Tagged 2012 OVDP, BANK SECRECY ACT, FBAR, FBAR PENALTIES, FOREIGN BANK ACCOUNTS, OFFSHORE ACCOUNTS, OFFSHORE BANK ACCOUNTS, OFFSHORE TAX FRAUD, OVDP, OVDP BENEFITS, ROBERT S STIENBERG, SWISS BANKS, TAX CRIMES, VOLUNTARY DISCLOSURE
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