IRS amnesty programs for late filers, including the Streamlined Procedures and voluntary disclosure.
On September 28, 2018, the IRS officially terminated its increasingly unpopular Offshore Voluntary Disclosure Program (OVDP), leaving willfully delinquent taxpayers open to the full gambit of…
Read MoreA key requirement for participating in the IRS’s Streamlined amnesty program is a certification by the late filer that his or her delinquency was the result of non-willful conduct.
Read MoreCurrently, over 9 million U.S. citizens are living outside the United States. More and more expats are beginning to realize that their U.S. tax obligations did not end upon their move abroad. Many…
Read MoreYesterday, the IRS announced that over the next several months, it will be steadily dismantling its Offshore Voluntary Disclosure Program (OVDP), before officially terminating the program by…
Read MoreFor many U.S. expats who are delinquent in their expat tax filings, the Streamlined Procedures offer a great solution for catching up with limited or no penalties. Due to the Streamlined program’s…
Read MoreIn a recently-posted blog, National Taxpayer Advocate Nina Olson discussed the potential pitfalls of treating information on the IRS’s website, such as its FAQs pages, as authoritative. The Taxpayer…
Read MoreIn a very recent decision (Maze v. IRS), the D.C. Circuit Court of Appeals upheld a lower court decision blocking several taxpayers’ efforts to leave the OVDP tax amnesty program and enter the…
Read MoreWith the recent heavy focus on Congress and the Trump’s administration’s tax reform proposals, it can be easy to forget that the IRS continues to proactively crackdown on offshore tax evasion.
Read MoreIn a recently published Chief Counsel Advice, the IRS chief counsel’s office offered advice to taxpayers participating in its tax amnesty programs regarding the issue of whether refunds for past…
Read MoreRecently, the IRS announced that it will focus its audit efforts this year on 13 particular compliance issues, which touch on large business and international activities. This issue-focused effort…
Read MoreIf you thought FBAR penalties were more bark than bite, a recent U.S. District Court case is sure to change your mind.
Read MoreThe IRS announced recently that since the inception of its amnesty programs in 2009, over 100,000 delinquent taxpayers have taken the plunge and decided that participation is their best option.…
Read More
