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Category: Offshore Accounts/International Tax Disputes

VDP vs. Streamlined Filing Compliance: What U.S. Taxpayers with Offshore Assets Need to Know

The IRS’s Voluntary Disclosure Practice (VDP) and its Streamlined Filing Compliance Procedures both provide ways for high-income and high-net-worth taxpayers to proactively resolve issues related to the disclosure (or non-disclosure) of their offshore assets. But, the VPD and Streamlined Filing Compliance Procedures are very different—each being subject to its own […]

Offshore Accounts/International Tax Disputes

IRS Issues Updated FAQs on the Voluntary Disclosure Practice (VDP)

The Voluntary Disclosure Practice (VDP) provides an avenue for high-income and high-net-worth taxpayers to resolve significant federal tax controversies without facing criminal prosecution. Administered by IRS Criminal Investigation (IRS CI), the VDP is a long-standing program that allows eligible taxpayers to mitigate their exposure and settle with the IRS—provided that […]


What Business Owners Need to Know About the Employee Retention Credit Voluntary Disclosure Program (ERC VDP)

The Internal Revenue Service (IRS) recently launched its highly anticipated Employee Retention Credit Voluntary Disclosure Program (ERC VDP). Under the ERC VDP, eligible businesses can resolve improper ERC claims without liability for interest or penalties. However, filing under the ERC VDP can be risky, and it isn’t the best option […]

Offshore Accounts/International Tax Disputes

Do I Need to File an FBAR for FY 2023 (and What Happens If I Don’t)?

Taxpayers that own (or control) offshore bank accounts and other foreign financial assets have a duty to report these assets to the federal government annually. While there are minimum thresholds for taxpayers’ reporting obligations, these thresholds are fairly low—so most high-income and high-net-worth taxpayers will need to comply. Typically, this […]


What Are the Concerns for Taxpayers Considering a Streamlined Filing?

The Internal Revenue Service’s (IRS) streamlined filing compliance procedures provide a way for U.S. taxpayers to mitigate the consequences of failing to disclose their foreign financial assets. Taxpayers who qualify to submit a streamlined filing are not subject to failure-to-file, failure-to-pay or accuracy-related penalties and instead pay a five-percent “miscellaneous […]