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Between the years 2009-2016, the IRS created three different Offshore Voluntary Disclosure Programs (IRS OVDPs) for U.S. taxpayers to voluntarily disclose their undeclared foreign accounts: 2009 Offshore Voluntary Disclosure Program (2009 OVDP), 2011 Offshore Voluntary Disclosure Initiative (2011 OVDI), and 2012 Offshore Voluntary Disclosure Program (2012 OVDP). 2012 OVDP was subsequently profoundly modified in the […]
The subject of this article is the discussion of the Form 872 Refund Claims, particularly whether filing Form 872 can extend the time for the taxpayer to claim a refund for the relevant years. Stated broadly, the key question that this article seeks to explore is whether an extension of time for assessment of tax […]
On October 26, 2016, the Totalization Agreement with Romania entered a new stage – the government of Romania approved for signature a draft social security (also known as “Totalization”) agreement with the United States. The Totalization Agreements are authorized by Section 233 of the Social Security Act. The United States currently has Totalization Agreements with […]
On October 28, 2016, the IRS reminded employers and small business owners of the new January 31, 2017 deadline as a result of the PATH Act. PATH Act’s Impact on the Filing Deadlines for Forms W-2 and 1099-MISC In the past, employers typically had until the end of February, if filing on paper, or the […]
As the headquarters of Berkshire Hathaway, Omaha (Nebraska) draws a large number of foreign-born professionals. A high percentage of these professionals still have foreign accounts overseas and they are in great needs of assistance from an Omaha FBAR attorney. Oftentimes, they cannot find an attorney they like in Omaha (especially, since this is not a […]