Tag Archive for Double Counting

OVDP & Double Counting: Traps For The Unwary

Accounting for “double counting” is not child’s play. Your tax attorney will need the following information in order to complete his or her review of your double counting issue. These steps must be repeated for every year in which you believe that there is a double counting issue.

For each transfer, you should provide the following:

(a) The highest balance of the account from which the transfer(s) was made for the tax year in question;

(b) The highest balance of the account into which the transfer(s) was made for the tax year in question; Read More

Written by | Posted in FBAR • OVDP

OVDP And Double Counting: Oh The Agony!

What is this phenomenon known as double counting? Why is it important? If you are shepherding clients through the OVDP program, or you are going through the program yourself, it is critical that you understand what it means and the governing principles behind it. Otherwise, you could be paying an offshore penalty that is exponentially higher than what it ought to be.

This article will explain the principles behind double counting and what type of supporting evidence the taxpayer must produce in order to prove double counting to the satisfaction of the IRS. As is my ordinary practice, I will make use of a hypothetical.

As a refresher, the offshore penalty is determined by isolating the highest aggregate Read More

Written by | Posted in OVDP