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2012 OVDP (Offshore Voluntary Disclosure Program) (now closed) may present a great opportunity for certain U.S. taxpayers to deal with their current as well prior non-compliance with U.S. tax laws. However, 2012 OVDP is not for everyone; while for certain categories of taxpayers it is the best option, other taxpayers may have additional choices that […]
One of the most important tax compliance forms for businesses and individuals is the Report of Foreign Bank and Financial Accounts (the “FBAR”), FinCEN Form 114 Formerly TD F 90-22.1. Pursuant to the Bank Secrecy Act, 31 U.S.C. §5311 et seq., the Department of Treasury (the “DOT”) has established certain recordkeeping and filing requirements for […]
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. In this article, I summarize some of the key penalties that such non-compliant U.S. taxpayers may face once the IRS finds them. Penalties in General In general, if the IRS verifies […]
As 2012 OVDP (Offshore Voluntary Disclosure Program) now closed enters its second tax season, it is important to review once again the reasons behind the existence of the program, what it offers to the IRS and how it may benefit currently non-compliant U.S. taxpayers. Focus on International Tax Compliance Since 2003, the IRS has conducted […]
In FinCEN Notice 2012-2, the Financial Crimes Enforcement Network (FinCEN) announced a third extension of time for certain Report of Foreign Bank and Financial Accounts (FBAR) filings in light of ongoing consideration of questions regarding the filing requirement and its application to individuals with signature authority over but no financial interest in certain types of […]