Entries by Manager

Tax Lawyers Minneapolis | IRS Increases Interest Rates for the Second Quarter of 2011

The Internal Revenue Service announced that the interest rates for the calendar quarter beginning April 1, 2011, will increase by one percentage point. Under the Internal Revenue Code, the rate of interest is determined on a quarterly basis. For taxpayers other than corporations, the overpayment and underpayment rate is the federal short-term rate plus 3 […]

2011 Offshore Voluntary Disclosure Initiative vs. Statute of Limitations

As I already described in an earlier article, the IRS instituted a new voluntary disclosure program, called 2011 Offshore Voluntary Disclosure Initiative (“OVDI”). One of the most problematic areas under OVDI is the length of the examination period. Agreeing to assessment of taxes and penalties for all voluntary disclosure years is part of the resolution […]

Failure to Conduct Voluntary Disclosure: Possible Penalties

The IRS just instituted a new voluntary disclosure program for taxpayers (now closed) who have offshore accounts or assets and who failed to properly report them to the IRS and pay appropriate U.S. taxes. It is called 2011 Offshore Voluntary Disclosure Initiative (“2011 OVDI”). While 2011 OVDI is not available for everyone and some particular […]

2011 Offshore Voluntary Disclosure Initiative

On February 8, 2011, the Internal Revenue Service announced that a new 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, will be available through August 31, 2011. The IRS decision to open a […]