Author Archive for: Tax Attorney

The changes announced by IRS on June 18, 2014 make important modifications to the Offshore Voluntary Disclosure Program (“OVDP”). The changes include: Requiring additional information from taxpayers applying to the program; Eliminating the existing reduced penalty percentage for certain non-willful taxpayers in light of the expansion of the streamlined procedures; Requiring taxpayers to submit all […]

The IRS has authority to assert FBAR civil penalties.  Before delving into the FBAR abyss, this is a good time to debunk some FBAR myths.  First, there is no such thing as an FBAR penalty within the Offshore Voluntary Disclosure Initiative (“OVDI”).  The FBAR penalty exists only outside of the OVDI framework.  However, there is […]

With more than six million U.S. citizens living abroad, the IRS is looking to expand its net to bring in those U.S. Expats who are noncompliant with their tax obligations but are not willfully evading taxes may to come into compliance.  On June 3, 2014, the Commissioner of the Internal Revenue Service, John A. Koskinen, […]

A taxpayer who has not disclosed foreign bank accounts to the IRS can be charged with substantial miscellaneous Title 26 offshore penalties that ultimately can wipe out a taxpayer’s foreign assets.  Disclosure is made by e-filing FinCEN Form 1114 (formerly Form TD F 90-22.1), Report of Foreign Bank and Financial Accounts (“FBAR”).  The civil penalty […]

A taxpayer who has not disclosed foreign bank accounts to the IRS and to cure this delinquency and avoid criminal repercussions applies to the Offshore Voluntary Disclosure Initiative (“OVDI”), generally must pay a miscellaneous Title 26 offshore penalty, in lieu of traditional penalties that would apply to foreign assets or entities outside of OVDI.  The […]