There has been a potentially landscape-altering decision out of the Fifth Circuit Court of Appeals (Court) regarding Reports of Foreign Bank and Financial Account (FBAR) penalties. In United States v. Bittner, that Court has held that each failure to report a qualifying account is a separate violation. This is a significant split from the Ninth [...]
People often joke that the only certainties in life are death and taxes. Well, it turns out that, when it comes to the report of Foreign Bank and Financial Account (FBAR) penalties, death may have finally met its match. The Southern District of Florida issued a decision in United States v. Green, 2020 BL 165965 [...]
The Internal Revenue Service’s (IRS’s) Offshore Voluntary Disclosure Program (Program) has elements of the Program that will no longer be available to certain taxpayers on September 28, 2018. For more on those elements, please see our previous posts here and here. Following the IRS’s decision to eliminate elements of the Program, it also issued Technical [...]
Offshore Voluntary Disclosure Program Ends September 28, 2018 The IRS recently announced that it will end its Offshore Voluntary Disclosure Program (OVDP) on September 28, 2018. To participate in the OVDP before it ends on September 28, 2018, a taxpayer must submit a complete offshore voluntary disclosure. The disclosure must (1) conform to the requirements [...]
Defaulted Installment Agreements The IRS expects taxpayers to pay all of their tax liabilities in full, at the latest, at the time the liabilities are due. When this is not possible, the IRS may allow taxpayers to pay their liabilities during a period of time through a monthly payment plan. These payment plans are called [...]
This is the sixth article in the Offshore Voluntary Disclosure Program (OVDP) Frequently Asked Questions series. This series is intended to provide taxpayers and practitioners with answers to the most commonly asked questions relating to the Internal Revenue Service’s (IRS’s) 2012 OVDP. Other posts in this series, offering a basic description of the OVDP and [...]
This is the fifth article in the Offshore Voluntary Disclosure Program (OVDP) Frequently Asked Questions series. This series is intended to provide taxpayers and practitioners with answers to the most commonly asked questions relating to the Internal Revenue Service’s (IRS’s) 2012 OVDP. Other posts in this series, offering a basic description of the OVDP and [...]
This is the fourth article in the Offshore Voluntary Disclosure Program (OVDP) Frequently Asked Questions series. This series is intended to provide taxpayers and practitioners with answers to the most commonly asked questions relating to the Internal Revenue Service’s (IRS’s) 2012 OVDP. Other posts in this series, offering a basic description of the OVDP and [...]
This is the third article in a series regarding Frequently Asked Tax Questions relating to the Internal Revenue Service’s (IRS’s) Offshore Voluntary Disclosure Program (OVD Program). This series is intended to answer program participants’ most common questions. The first and second posts in this series, offering a basic description of the OVD Program and some [...]
This is the second article in a series regarding Frequently Asked Tax Questions relating to the Internal Revenue Service’s (IRS’s) Offshore Voluntary Disclosure Program (OVD Program). This series is intended to answer program participants’ most common questions. The first post in this series, offering a basic description of the OVD Program, can be found here. [...]