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The Voluntary Disclosure Period for the taxpayers who entered into the now closed IRS Offshore Voluntary Disclosure Program (“OVDP”) encompasses an eight-year period during which the FBAR form may have been modified more than once. The question arises about what version of the FBAR form should be used in the OVDP. FBAR Background Pursuant to […]
In an earlier article, I already described the general process of the Offshore Voluntary Disclosure Program. In that article, I mentioned that you must make a complete submission of your Voluntary Disclosure Package within 90 days of the date of the preliminary acceptance letter from the IRS Criminal Investigation. What if you cannot make a […]
On February 14, 2013, the U.S. Department of the Treasury announced that it has signed a bilateral agreement with Switzerland to implement the information reporting and withholding tax provisions commonly known as the Foreign Account Tax Compliance Act (FATCA). Enacted by Congress in 2010, FATCA targets non-compliance by U.S. taxpayers using foreign accounts. The bilateral […]
In an earlier article, I discussed the key requirements of the Offshore Voluntary Disclosure Program (OVDP) now closed. In this essay, I would like to outline the general OVDP administrative process from initial pre-clearance through the execution of the Closing Agreement. General Description In order to participate in the OVDP, the taxpayer must first be […]
There are some taxpayers who should not be using the official IRS Offshore Voluntary Disclosure Program (OVDP) now closed. The IRS expressly singled out one category of such taxpayers in its Q&A 17 of the OVDP Rules. Q&A 17 only applies to the taxpayers who reported and paid tax on all their taxable income for […]