Category Archives: Streamlined Offshore Procedures

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 ...

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.” 

Will Travel Insurance Cover This? Your Passport Can Be Denied or Revoked for Seriously Delinquent Taxes

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 ...

Jerry Lucente Speaks

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 14653

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.