Entries by Manager

Understand How IRS Amnesty Works Before Entering 2014 OVDP

Less than two months are left before the 2014 IRS Offshore Voluntary Disclosure Program (“2014 OVDP”) closes on September 28, 2018. 2014 OVDP may offer great benefits to taxpayers with undisclosed foreign accounts, such as the possibility of avoiding criminal penalties and greatly reducing FBAR civil penalties. Yet, entering 2014 OVDP also implies a great […]

Streamlined Domestic Offshore Procedures Audits | SDOP Tax Lawyer

The great majority of offshore voluntary disclosures are currently done through Streamlined Filing Compliance Procedures. Hence, the majority of IRS audits concerning offshore voluntary disclosures are focused on Streamlined Filing Compliance Procedures – the most common type is the Streamlined Domestic Offshore Procedures Audit. This article discusses the main stages of the Streamlined Domestic Offshore […]

2018 FBAR Civil Penalties | FBAR Tax Lawyer & Attorney

Following the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015, the FBAR civil penalties are adjusted every year by the IRS for inflation. In this brief article, I would like to describe the new 2018 FBAR Civil Penalties that may be assessed by the IRS with respect to FBAR noncompliance. 2018 FBAR Civil […]