Tag Archive for OVDP

Streamlined OVDP’s “Nonwillful Narrative” Requirement

TaxConnections Picture - Money In Sand 3 - square

Taxpayers using either the Streamlined Foreign Offshore Procedures or the Streamlined Domestic Offshore Procedures, will be required to certify, that the failure to report all income, pay all tax and submit all required information returns, including FBARs (FinCEN Form 114, previously Form TD F 90-22,1) was due to Non-Willful Conduct.

The IRS’s OVDP Streamlined Procedures Forms require taxpayers to provide a narrative statement of facts, explaining their failure to disclose their offshore assets, or the IRS will consider the applications incomplete and the taxpayer won’t get Streamline Relief. The IRS Streamlined Filing Compliance Procedures website provides:

“Failure to submit this statement, or submission of an incomplete or otherwise Read more

Hiding Money Or Income Offshore Among The List Of Tax Scams For The 2015 Filing Season

TaxConnections Picture - Jail - Prisoner - 1 - square

IRS Commissioner John Koskinen was proud to announce that “the recent string of successful enforcement actions against offshore tax cheats and the financial organizations that help them shows that it’s a bad bet to hide money and income offshore and he encouraged taxpayers to come in voluntarily and getting their taxes and filing requirements in order.”

Since the first Offshore Voluntary Disclosure Program (OVDP) opened in 2009, the IRS reports there have been more than 50,000 disclosures and the IRS has collected more than $7 billion from this initiative alone. The IRS also has conducted thousands of offshore-related civil audits that have produced tens of millions of dollars. Finally, the IRS has also pursued criminal charges leading to billions of dollars in criminal fines and Read more

How Do You Know When You’re In Trouble With The Government? When The Name of Your Trust Is “Cappuccino” Spelled Backwards

TaxConnections Picture - Coffee Cup - Cappucino - square

The U.S. Attorney’s Office for the Southern District of New York issued a press release on January 20, 2015 announcing the guilty plea of a CEO for hiding over $ 8.4 million in offshore Swiss bank accounts. George Landegger, the Chairman and CEO of an international pulp mill company, pled guilty to willfully failing to file FBARs for accounts that he maintained at a Swiss bank located in Zurich, Switzerland.

Landegger owned these accounts for nearly ten years, from the early 2000s up until 2010. During that time, his undeclared assets reached a high value of over $8.4 million.

What got Mr. Landegger into this “hot mess?” At the most primitive level, Mr. Landegger failed to report numerous Swiss bank accounts that he held for nearly ten years. But like Read more

OVDP Program Open Indefinitely For Taxpayers Hiding Money or Income Offshore!


The Internal Revenue Service today January 28, 2015, said in its news release (IR-2015-09), that avoiding taxes by hiding money or assets in unreported offshore accounts remains on its annual list of tax scams known as the “Dirty Dozen” for the 2015 filing season.

“The recent string of successful enforcement actions against offshore tax cheats and the financial organizations that help them shows that it’s a bad bet to hide money and income offshore,” said IRS Commissioner John Koskinen.

“Taxpayers are best served by coming in voluntarily and getting their taxes and filing requirements in order.”

Since the first Offshore Voluntary Disclosure Program (OVDP) opened in 2009: Read more

Sovereign Management In Panama Now Under DOJ/IRS Investigation

TaxConnections Picture - Agent 5 - square

Important announcement to U.S. taxpayers that opened offshore bank accounts through a company called Sovereign Management & Legal, Ltd. Based in Panama, the company offers to help Americans open offshore bank accounts with nominee corporations. Knowing that many people who do take these actions are also committing tax evasion, the IRS and Justice Department obtained a John Doe summons from a federal judge. The IRS hopes to find Americans who used Sovereign to open accounts.

Federal Court Approves U.S. Government Issuance Of John Doe Summonses

A Federal Judge recently approved the Internal Revenue Service’s issuance of what is known as a “John Doe” summons to several entities in the U.S who utilized the services Read more

Walking The Sawdust Trail

TaxConnections Picture - Evangelist - square

Those who responded to the altar call after one of Billy Sunday’s sermons (see video below) were said to walk the sawdust trail, because the temporary venues he preached in back in the 1910s and 1920s often had sawdust on the floor as a deodorizer.

Before he became a travelling evangelist, and possibly even before he became a Christian, depending on what source you believe, Mr. Sunday played eight seasons of Major League Baseball between 1883 and 1890. During that time, he roamed the outfield for the Chicago White Stockings, Pittsburgh Alleghenys and Philadelphia Phillies. Mr. Sunday left the game with a lifetime .248 batting average, which was pretty good for the pre-modern era. He was also a speedy player who finished in the top ten in stolen bases three times and led the league in outfield putouts in 1888. Read more

U.S. Treasury Publishes Official FBAR Exchange Rates for 2014

U.S.Treasury To Insure Money Market Mutual Funds

Anyone filing an “FBAR” (Report of Foreign Bank and Financial Accounts – FinCEN Form 114) or IRS Form 8938 (Statement of Foreign Financial Assets) for calendar year 2014 will be pleased to know that the official exchange rates for 2014 have been published. As U.S. law states that no other exchange rate is permitted, it is really helpful to have these exchange rates available so early in January.

Exchange rates for other currencies can be found by clicking here.

The rates for the major foreign currencies are listed below:


Read more

National Taxpayer Advocate Lambasts IRS’s OVDP Programs And FBAR Penalties

TaxConnections Picture - C - square

Here ye, here ye! National Taxpayer Advocate, Nina Olson recently gave her annual report to Congress. And she didn’t mince words. She lambasted the IRS for relentlessly asserting onerous offshore penalties including its disproportionate treatment of non-willful taxpayers caught in the labyrinth of foreign asset reporting. Ms. Olson’s report asks the IRS to change its ways and to end the practice of branding every taxpayer who happens to have an offshore account with the letter “C” for “criminal.” Indeed, this is not the year 1652 and not every taxpayer who has an offshore account is the modern-day equivalent of Hester Prynne, the young woman found guilty of adultery in “The Scarlet Letter” and forced to wear a scarlet “A” (“A” was the symbol of adultery) on her dress to shame her. Read more

Don’t Believe The Seven Deadly Myths Of FATCA Non-Enforcement

Top secret! - Young businessman with finger on his lips
This May Be Your One Last Opportunity to Avoid Criminal Prosecution and Increased Civil Penalties!

Since July 1, 2014, the most feared U.S. legislation regarding international tax enforcement – Foreign Account Tax Compliance Act (“FATCA”) – is being implemented by most banks around the world. As part of this compliance, foreign banks from around the world are sending letters to account holders that they believe have, or had, a U.S. tax nexus (or other U.S. connection) requesting information to determine whether such account holders have disclosed their foreign bank accounts to the IRS. The letters from foreign banks generally require an account holder to disclose whether the account has been declared to the IRS through the filing of a Report of Foreign Bank and Financial Accounts (commonly known as Read more

London Mayor Refuses To Pay U.S. Tax Bill

TaxConnections Picture - London England - square

London Mayor Boris Johnson is being pursued by U.S. tax officials while his former New York counterpart Michael Bloomberg was given an honorary knighthood by Queen Elizabeth last month.

Beware As The U.S. Tax Net Closes On Thousands Of U.S. Citizens Living Abroad.

The Conservative mayor of London – who was born in New York and holds an American passport – just revealed he is being pursued by the U.S. authorities for an unpaid tax demand. The demand reportedly relates to his first home in the UK, which he said was not subject to capital gains tax in England. According to U.S. tax law all citizens are required to file a tax return and pay U.S. taxes, even those with dual citizenship and Read more

Not On My Watch


When European financial giant Credit Suisse AG pleaded guilty to assisting U.S. taxpayers evade federal income tax, there was a great deal of swagger at the Justice Department. Former Attorney General Eric Holder, in classic Clint Eastwood style, boldly proclaimed that “no financial institution. . .is above the law,” and that any other bank which dared engage in such “brazen misconduct” would be “prosecut[ed] to the fullest extent possible.” Not to be outdone, Deputy AG James Cole warned investors that, if government investigators began asking questions, “[o]nly through full cooperation will you avoid the most severe sanctions.”

Tough words, indeed. But what is behind the Justice Department’s bravado, and what options do you have if you get a not-so-friendly phone call or if authorities suddenly Read more