Entries by Manager

What Needs to Be Included in the OVDP Preclearance Request

The OVDP Preclearance Request is a very important document that is required to be filed in order to commence a US taxpayer’s voluntary disclosure under the 2014 IRS Offshore Voluntary Disclosure Program (2014 OVDP) which is still in existence at the time of this writing. This is why it is important to understand what actually […]

Form 8938 Definition of Foreign Financial Institution

Financial accounts maintained by a Foreign Financial Institution constitute one of the main categories of Specified Foreign Financial Assets that need to be reported on IRS Form 8938. While it seems trivial, it is important to understand what is meant by “Foreign Financial Institution” within the context of Form 8938 – i.e. what is the Form […]

Higher OVDP Penalty Risk for US Taxpayers With Foreign Accounts

December of 2015 was one of the most successful months for the DOJ’s Swiss Bank Program as nearly a record number of banks signed non-prosecution agreements. This success for the DOJ means that more and more of non-compliant US taxpayers with foreign accounts are likely to deal with Higher OVDP Penalty with respect to their […]