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On March 1, 2013, the IRS announced that the underpayment and overpayment interest rates will remain the same for the calendar quarter beginning April 1, 2013. The rates will be: three (3) percent for overpayments [two (2) percent in the case of a corporation]; three (3) percent for underpayments; five (5) percent for large corporate […]
In another essay, I previously discussed the possible inclusion of the business ownership interests in the calculation of the OVDP (2012 Offshore Voluntary Disclosure Program) Offshore Penalty. In this article, I would like to explore in more depth the application of the Offshore Penalty to ownership of business interests. OVDP Offshore Penalty It is a […]
The taxpayers who enter into the IRS Offshore Voluntary Disclosure Program (“OVDP”) often have failed to file an FBAR to report an account over which the taxpayer has signature authority. The question arises about whether such accounts should be included in the calculation of the OVDP Offshore Penalty? The answer to this question is – […]
In an earlier article, I introduced the structure of the OVDP (Offshore Voluntary Disclosure Program) Offshore Penalty. In this essay, I would like to explore one aspect of that structure – the possibility of reducing the Offshore Penalty to 12.5%. Offshore Penalty The taxpayers who enter the OVDP must pay the Offshore Penalty. This penalty […]
Before one enters into the 2012 Offshore Voluntary Disclosure Program (“OVDP”), it is highly important to understand what kind of assets are covered by the OVDP Offshore Penalty. In this essay, I intend to broadly outline some of the major types of assets covered by the OVDP Offshore Penalty. From the outset, it is important […]