Rather than request to participate in one of the IRS’s Offshore Voluntary Disclosure programs and submit themselves to the arduous process and a miscellaneous percentage penalty based on account balances, some taxpayers have chosen to simply submit a few years’ worth of amended returns to an IRS service center, submit […]
As we talk to our clients about their options with regard to reporting their previously undisclosed foreign accounts to the IRS, we’ve noticed a new term pop-up recently. This term is “Qualified Quiet Disclosure.” The first, and most important thing to understand, is that the IRS does not “qualify” quiet […]
In response to widespread criticism of the strict penalties associated with the IRS Offshore Voluntary Disclosure programs, the IRS designed a different program for certain qualifying taxpayers. Non-Resident United States Taxpayers The Streamlined Offshore Voluntary Disclosure is a procedure designed for taxpayers that represent a low-compliance risk to the Internal […]
Taxpayers who are willing to certify that their failure to report foreign financial assets and the related income was non-willful may be eligible to make a disclosure under one of the new Streamlined Offshore Programs. There are two different programs available, one for non-resident U.S. taxpayers, and one for resident […]
It is not illegal for U.S. taxpayers to maintain accounts at foreign financial institutions, invest in foreign assets, or own foreign-controlled corporations. However, U.S. taxpayers with foreign assets must fulfill various reporting requirements under the Bank Secrecy Act and the Internal Revenue Code. Below is a list of commonly-missed forms […]
Texas FATCA Lawyer: Legal Guidance If you have a foreign bank account, you may have recently received correspondence from your foreign financial institution informing you of their intent to turn over your information, as a U.S. taxpayer, to the IRS. These notices are being sent out in response to foreign […]
The Foreign Account Tax Compliance Act is the most significant legislation enacted to date in the area of offshore account compliance. The United States has aggressively sought to implement the Foreign Account Tax Compliance Act, obtaining Intergovernmental Agreements with a number of nations and we expect that many more nations […]
In August 2013, the U.S. Department of Justice, in conjunction with the Swiss Federal Government, announced a compliance program that enables Swiss financial institutions to address and resolve their status with the U.S. Department of Justice. Similar to the Offshore Voluntary Disclosure Programs that have been made available to U.S. […]
For U.S. taxpayers who have not yet disclosed foreign accounts and who are trying to decide what to do, a review of the related Offshore Voluntary Disclosure Program statistics is often helpful. As of late 2013, the United States Department of Justice had indicted approximately 120 taxpayers or taxpayer advisors […]
National Offshore Voluntary Disclosure Program (OVDP) Lawyers In addition to the 2009, 2011, and 2012 Offshore Voluntary Disclosure Programs, the IRS has also offered and continues to offer a voluntary disclosure program for tax matters unrelated to foreign income and asset issues. Under this program, taxpayers may be granted amnesty […]