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 [...]
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. [...]