Category Archives: Streamlined Offshore Procedures
March 15, 2018
by Attorney Patricia Weisgerber, Esq. 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 ...
February 19, 2018
Wire Transfer Audits and FATCA
What Every Taxpayer Needs to Know
by Attorney Morris N. Robinson, CPA, LLM
February 19, 2018
1. FATCAFATCA: The Foreign Account Tax Compliance Act was signed into law by President Obama on March 18, 2010. There ...
June 22, 2017
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 ...
June 14, 2017
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 ...
April 5, 2017
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.”
Will Travel Insurance Cover This? Your Passport Can Be Denied or Revoked for Seriously Delinquent TaxesJanuary 6, 2016
If you wrote “travel more” on your 2016 New Year’s resolutions list, you may want to make sure you’re in good standing with the IRS before you make plans to wander too far from home. In early December 2015, legislation was enacted to add section 7345 titled “Revocation or Denial ...
December 16, 2015
Jerry Lucente is a Small Business/Self Employed Territory Manager with the North Atlantic Region of IRS, which includes the six New England states, New York and New Jersey. He is responsible for four groups at IRS that comprise about 100 employees. On Tuesday, December 15, 2015, Jerry spoke informally at ...
IRS Clarification on Non-Willful Conduct Certification for Streamlined Offshore Compliance Procedures: Revisions to IRS Forms 14654 and 14653February 26, 2015
Many U.S taxpayers are often surprised to discover that they have a U.S. tax reporting obligation on financial accounts or assets held overseas. Once they discover their obligation, there are a number of programs through which they can become compliant with their U.S. tax reporting obligation. One option, if the taxpayers meet the requirements, is to submit either IRS Form 14654 or IRS Form 14653 for the Streamlined Domestic Offshore Procedures or the Streamlined Foreign Offshore Procedures, respectively. These forms require U.S. taxpayers to certify that their prior non-compliant conduct was non-willful. However, not much guidance exists regarding what information is needed as part of this certification. A recent change by the IRS to these forms has provided some clarity.