Accountants Beware: FBAR Disclosure is a Legal Matter
Paradoxically, one of the obstacles currently facing U.S. taxpayers who wish to file their delinquent FBARs and conduct a voluntary disclosure of their foreign [...]
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Read more →12.5% OVDP Offshore Penalty Category
In an earlier article, I introduced the structure of the OVDP (Offshore Voluntary Disclosure Program) Offshore Penalty. In this essay, I would like to [...]
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Read more →Domestic and Offshore Voluntary Disclosure Ineligibility Examples
In an earlier article, I discussed the general Offshore Voluntary Disclosure Program eligibility requirements, particularly those spelled out in the Internal Revenue Manual (IRM). [...]
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Read more →Offshore Accounts Disclosure and John Doe Summons
If a taxpayer is about to conduct a voluntary disclosure of his offshore accounts, a question arises about his eligibility to do so in [...]
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Read more →Failure to Conduct Voluntary Disclosure and Potential Penalties: 2013 Update
Failure to conduct voluntary disclosure may mean heavy penalties for U.S. taxpayers are not in compliance with international tax laws established by U.S. government. [...]
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