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Tag Archive for OVDP

IRS Crackdown And The Future Of Tax Amnesty Programs

Ephraim Moss

With the recent heavy focus on Congress and the Trump’s administration’s tax reform proposals, it can be easy to forget that the IRS continues to proactively crackdown on offshore tax evasion. Read more

Offshore Tax Suit Switch From OVDP Doesn’t Block Collection

Ron Marini

Three taxpayers seeking to switch over to the IRS’ new “streamlined” compliance program for unreported offshore income argued to a D.C. Circuit panel Tuesday that their lawsuit is not foreclosed by the Anti-Injunction Act’s bar on pre-enforcement tax challenges, attacking the government’s key defense in the case. The case is Maze et al. v. Internal Revenue Service et al., case number 16-5265, in the U.S. Court of Appeals for the District of Columbia Circuit.

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IRS Launches 13 Audit Campaigns Targeting Businesses

Ephraim Moss

Recently, the IRS announced that it will focus its audit efforts this year on 13 particular compliance issues, which touch on large business and international activities. This issue-focused effort contrasts with the more broad-based approach that the IRS has previously taken with respect to auditing taxpayers.

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IRS Committed To Stopping Offshore Tax Cheating

Ron Marini

The Internal Revenue Service today said avoiding taxes by hiding money or assets in unreported offshore accounts remains on its 2017 list of tax scams known as the “Dirty Dozen.”

Since the first Offshore Voluntary Disclosure Program (OVDP) opened in 2009, there have been more than 55,800 disclosures and the IRS has collected more than $9.9 billion from this initiative alone.In addition, another 48,000 taxpayers have made use of separate streamlined procedures to correct prior non-willful omissions and meet their federal tax obligations, paying approximately $450 million in taxes, interest and penalties.

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Be Careful What You “Fix For” – Mr. Kentera Meets Mr. FBAR

John Richardson

The “unfiled FBAR” continues to be a problem for certain Homeland Americans with “offshore accounts” and all Americans abroad, who continue to “commit personal finance abroad”.

Introducing Mr. and Mrs. Kentara

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A Holiday Gift: What To Do About The Unfiled FBAR – Part 2

John Richardson

Yesterday, we started this blog post to hopefully encourage those with U.S. tax issues to consider whether they can deal with minor/unintentional FBAR violations as a “stand alone single problem”. There may be no need to escalate and expand one single problem into a multi-dimensional full blown tax problem that may end up with unintended and unanticipated costly professional fees as well as undue time spent! Read on and learn why. Keeping a calm head is most important, even if it is most difficult to do in the face of the scary situation of not being in compliance with the U.S. tax and regulatory regime.

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Paying Too Much CGT? Pravin Gordhan’s Tax Rate Reprieve

Hugo van Zyl

During February 2016 the beleaguered South African Minister of Finance, Minister Pravin Gordhan, made a serious attempt to balance government’s books.

Gordhan was called back after Minister Nene was removed from his position, by President Zuma early December 2015. The true reason for this politically motivated musical chairs, appointing three ministers in less than 4 days, remains a mystery. Point is Nene was removed and Gordhan had to step in and rescue the cash flow and ensure the country did not face junk status.

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Is This Canadian Baby An American Tax Cheat?

Is This Canadian Baby An American Tax Cheat?

A Canadian baby is learning about taxes, banking and activism at a tender age. The eight month old girl received a “Dear Valued Customer” letter from her Canadian bank when she was six months old advising her that her account information may be provided to Canada Revenue Agency to pass on to IRS.  The wee “Valued Customer” was directed to complete, sign and mail forms to the bank.

Baby Elle (not her real name) and her Canadian parents were Read more

Hiding Money Offshore Resides on the Dirty Dozen List of Tax Scams for the 2016 Filing Season

On Thursday, February 11, 2016 we posted IRS “Dirty Dozen” Tax Scams for 2015 we discussed that the Internal Revenue Service wrapped up the 2015 “Dirty Dozen” list of tax scams today with a warning to taxpayers about aggressive telephone scams continuing coast-to-coast during the early weeks of this year’s filing season, where it stated that avoiding taxes by hiding money or assets in Read more

93 Swiss Banks Are Turning Over Your Names To The IRS – What Are Your Waiting For?

Ronald Marini

The IRS keeps updating its list of foreign banks which are turning over the names of their US Account Holders, who are now subject to a 50% (rather than 27.5%) penalty in the IRS’s Offshore Voluntary Disclosure Program (OVDP). This penalty is based on the highest account balance measured over up to eight years.  On January 25, 2016 the Justice Department Announced that Leodan Privatbank AG (Leodan) is the 93rd Swiss Bank to reached a resolution under the department’s Swiss Bank Program.

Under the program, banks are required to:

Make a complete disclosure of their cross-border activities; Read more

Its Official – The the 5th Amendment DOES NOT Trump the Required Records Doctrine!

On Tuesday, October 27, 2015, we posted US Supreme Court Asked to Consider Whether the 5th Amendment Trumps the Required Records Doctrine? were we discussed the Third Circuit ruling that a married couple must turn over their foreign bank account records to the Internal Revenue Service, saying the couple can’t shield themselves by asserting their Fifth Amendment right against self-incrimination.

This comes after our post “Fifth Amendment Does Not Apply to Offshore Banking Records,” where we discuss that under the Required Records Doctrine, and a taxpayer who is the subject of a grand jury investigation into his use of offshore bank accounts cannot invoke the privilege to resist compliance with a subpoena seeking records kept pursuant to the Bank Secrecy Act, the U.S. Court of Read more

Finally The Senate Foreign Relations Committee Approves 8 Tax Treaties!

We previously posted on November 2, 2015, Republican and Democratic Lawmakers Vow to Push Tax Treaties Delayed by Sen. Paul! where we discussed that over a year ago, we posted U.S. Senator Rand Paul Continues To Block 5 Important Tax Treaties where we discussed that the U.S.-Switzerland tax treaty remains stuck in the Senate after Sen. Rand Paul (R-Ky.) blocked an effort to propel it forward by Senate Foreign Relations Committee Chairman Robert Menendez (D-N.J.) When a bipartisan Senate panel lambasted Swiss bank Credit Suisse for helping rich Americans evade billions in taxes, some watching the high-profile hearing couldn’t help but notice that Sen. Rand Paul sticks out like a elephant in the room. Senator Rand Paul on Wednesday June 4, 2014 again blocked the U.S. Senate from moving toward ratifying five pending tax treaties, saying they would make it easier for foreign governments to invade the privacy of Americans. Now Treaties with: Read more

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