Category Archives: International Tax

IRS Is Closing Offshore Voluntary Disclosure Program; Deadline of September 28, 2018

The IRS announced it will be closing its Offshore Voluntary Disclosure Program (OVDP) as of September 28, 2018. The news follows a significant decrease in taxpayer participation in the program, coupled with advances in third-party reporting of offshore account information and increased awareness of reporting obligations. All submissions made by the deadline must ...

Wire Transfer Audits and FATCA: What Every Taxpayer Needs to Know

Wire Transfer Audits and FATCA

What Every Taxpayer Needs to Know

by Attorney Morris N. Robinson, CPA, LLM

February 19, 2018

1. FATCA

FATCA: The Foreign Account Tax Compliance Act[1] was signed into law by President Obama on March 18, 2010. There ...

International Tax Issues Are A Major Focus of Newest Launch of IRS Compliance Campaigns in 2017

Earlier this year, the IRS Large Business and International division (LB&I) rolled out 13 compliance campaigns[1] to target both individual taxpayers and corporations for examinations on certain tax compliance issues. On November 3, 2017, IRS announced the identification of an additional 11 compliance campaigns to be conducted by ...

FBAR Penalties Now Adjusted for Inflation: Abatement/Mitigation Still Possible

If you haven’t filed your Report of Foreign Bank and Financial Accounts (FBARs) on a timely basis, you could be at risk of a higher civil penalty assessment. Inflation-adjusted FBAR penalties are now in effect. New FBAR Civil Penalties Framework The statutory civil penalties most people are familiar with, and as reflected ...

2017 OVDP Declines and Withdrawals Campaign: Certain U.S. Taxpayers at Risk of Audit

In 2016, the Treasury Inspector General for Tax Administration (TIGTA) released a report which assessed how well that IRS was managing the Offshore Voluntary Disclosure Program (OVDP). OVDP is one of the programs taxpayers may use to become compliant if they previously had failed to report offshore income on their ...

Federal Tax Reform Legislation in 2017: Comments by Attorney Morris N. Robinson

Attorney Morris N. Robinson, the Managing Director of M. Robinson Tax Law in Boston, recently published an op-ed titled: Viewpoint: A 15 percent tax rate on business would maximize economic growth (Boston Business Journal, May 5, 2017, subscription required).

IRS Agent Discusses the Look-Back Period for Filing Delinquent International Information Returns

We represent a client who may need to file delinquent international information returns under the IRS Delinquent International Information Return Submission Procedures.  These procedures invite taxpayers who meet the specified criteria to “file the delinquent information returns with a statement of all facts establishing reasonable cause for the failure to file.” 

Building Wealth through Real Estate: Financial and Tax Policies of the United States Government That Can Lead To Significant Wealth through Real Estate Ownership

Financial and tax policies of the United States government can help Americans achieve significant wealth through real estate ownership. These policies tend to favor taxpayers who, like the Trump family, are willing to commit to "the long game”, where the full benefits of real estate ownership accrue over decades and ...

U.S. Citizens Retiring Abroad: “Tax Trigger” Situations and Related Disclosure Forms

The following is a bolded checklist of important situations that may “trigger” a tax review by a skilled United States tax professional. Many of these situations also require a simultaneous review by a foreign tax professional. It is generally best practice for these tax professionals to work together to minimize ...

The Power of Voluntary Taxpayer Disclosure

Today the Boston Globe reported that PTC, Inc. (“PTC”) voluntarily disclosed that its Chinese subsidiaries allegedly provided about $1.5 million in bribes to foreign officials over a period of five years (from 2006 through 2011) in violation of the United States Foreign Corrupt Practices Act. PTC is a publicly held ...