Entries by Manager

OVDI Deadline Extended until September 9, 2011

Due to the potential impact of Hurricane Irene, the IRS has extended the due date for offshore voluntary disclosure initiative requests until September 9, 2011. For those taxpayers who have not yet submitted their request and any documents, the following actions are necessary by September 9, 2011: Identifying information must be submitted to the Criminal […]

Post-OVDI Options: What to Do If You Cannot Make the OVDI Deadline

Introduction:  OVDI Deadline is August 31, 2011 On February 8, 2011, the Internal Revenue Service initiated  2011 Offshore Voluntary Disclosure Initiative (OVDI), a special voluntary disclosure initiative, designed to bring offshore money back into the U.S. tax system and help people with undisclosed income from hidden offshore accounts get current with their taxes.  While this […]

OVDI Deadline: August 31, 2011

This is a reminder that the  2011 Offshore Voluntary Disclosure Initiative (OVDI) will expire on August 31, 2011. The 2011 OVDI was announced on February 8, 2011, and follows the 2009 Offshore Disclosure Program (OVDP). The 2011 initiative offers clear benefits to certain taxpayers who currently face far higher penalties along with potential criminal charges […]

Recent Developments in Transfer Pricing

The IRS is currently examining new procedures and policies regarding transfer pricing audits. Recently, the IRS developed a “Transfer Pricing Practice” within its Large and Mid-Size Business (LMSB) operating division, and last August, the IRS realigned its Large Business & International (LB&I) operating division to handle international tax matters more effectively. The Service intends to […]