Tag Archives: Streamlined Procedures

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

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


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

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.