Although the Internal Revenue Service won’t comment on the reason Bank Leumi customers were kicked out of the IRS’ Offshore Voluntary Disclosure Program (OVDP) after not only being accepted into the program, but after some had already received a final clearance and paid the amounts due to the IRS, it is suspected that the IRS admitted the taxpayers into the program in error. If a taxpayer is already under investigation or audit, he won’t be admitted into OVDP. Once admitted, a taxpayer can be removed if he does not cooperate with the government or makes false statements with regard to the disclosure. Since some of these taxpayers were readmitted, it is likely they were originally admitted in error. Regardless, the right result was reached with this reversal if the IRS wants taxpayers to continue to come forward and disclose offshore accounts.
In accordance with Circular 230 Disclosure
Betty Williams has a broad range of experience handling civil and criminal tax controversy matters including income tax, employment tax, sales and use tax, property tax and IRS, FTB, and SBE audits, protests, and appeals. She has represented clients before the U.S. Tax Court and the U.S. District Courts in California. Betty has obtained penalty abatement for numerous clients ranging from a few thousand to more than $2 million in late filing and late payment penalties. She has assisted numerous clients in the United States and abroad in the 2009, 2011 and 2012 IRS and FTB voluntary disclosure initiatives. She also represents foreign financial institutions regarding Foreign Account Tax Compliance Act (FATCA) compliance. She has experience defending criminal tax matters and negotiating plea agreements in areas such as structuring, tax evasion, and the failure to file a tax return.
Subscribe to TaxConnections Blog
Post Views: 2,604
Recent Comments