Should I Stay or Should I Go? – Part 8

Access Leading Tax Experts And Technology
In Our Global Digital Marketplace

Written by Michael DeBlis, III | Posted in FBAR • OVDP

Answers to the Most Frequently Asked Questions Regarding OVDP

As a tax attorney specializing in the Offshore Voluntary Disclosure Program (OVDP), nary a day goes by that I don’t get a call from a person inquiring about the OVDP. The questions asked are relatively the same. After a while, I began to make a list of the most frequently asked questions. Below are my answers to them: (continued)

XI. I made a quiet disclosure by filing amended returns. Will the IRS audit me? If so, will I be eligible for OVDP?

The IRS is reviewing amended returns and could select any amended return for examination. It has identified, and will continue to identify, amended tax returns reporting increases in income.

The IRS will closely review these returns to determine whether enforcement action is appropriate. If a return is selected for examination, the taxpayer will no longer be eligible for OVDP.

Next: XII. I have properly reported all of my taxable offshore income. I only recently learned that I should have been filing FBARs in prior years to report my personal foreign bank account. Must I come forward to disclose this?

In accordance with Circular 230 Disclosure

Michael DeBlis, III

As a former public defender, Michael has defended the poor, the forgotten, and the damned against a gov. that has seemingly unlimited resources to investigate and prosecute crimes. He has spent the last six years cutting his teeth on some of the most serious felony cases, obtaining favorable results for his clients. He knows what it’s like to go toe to toe with the government. In an adversarial environment that is akin to trench warfare, Michael has developed a reputation as a fearless litigator.

Michael graduated from the Thomas M. Cooley Law School. He then earned his LLM in International Tax. Michael’s unique background in tax law puts him into an elite category of criminal defense attorneys who specialize in criminal tax defense. His extensive trial experience and solid grounding in all major areas of taxation make him uniquely qualified to handle any white-collar case.