Concerned about the IRS's OVDP and FATCA
Will a taxpayer qualify for either of the Streamline Program or the Offshore Voluntary Disclosure Program that permits taxpayers to voluntarily disclose their offshore bank accounts with reduced penalties if they are under examination?
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Tax Professional Answers
Richard Lehman, JD, LLM
Taxpayers who are already under a civil examination of a taxpayer’s returns for any taxable year, (regardless of whether the examination related to undisclosed foreign financial assets), will not be eligible to use the streamlined procedures or the Offshore Voluntary Program. Taxpayers under examination may consult with their agent. Similarly, a taxpayer under criminal investigation by IRS Criminal Investigation is also ineligible to use the streamlined procedures.
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483 weeks ago