MEANING OF CURRENTLY UNDER EXAMINATION FOR PURPOSES OF OVDP FAQ 14 Frequently Asked Question (FAQ) 14 of the 2014 edition of the Offshore Voluntary Disclosure Program asks: Question: “I’m currently under examination. ...
Author: PaperStreet Web Design
A Wall Street Journal of March 14, 2015 by Laura Saunders reveals how Gregg Kaminsky and his tax advisors violated the cardinal rule of voluntary disclosure practice, “Don’t make things worse than they already are.”...
STREAMLINED NON-WILLFUL CERTIFICATIONS: DON’T LIE, DON’T’ EXAGGERATE AND DON’T CHERRY-PICK YOUR FACTS
March 9, 2015
The Department of Justice Tax Division acting assistant attorney general, Caroline Ciraolo, speaking at the Federal Bar Association Tax Section annual tax conference (reported by Nathan J. Richman, Tax Analysts Tax Notes...
IRS OFFICIALS ANSWER CIVIL AND CRIMINAL OFFSHORE QUESTIONS
February 26, 2015
On February 24, 2015 I participated in an ABA Tax Section Webinar, “Answering Your Criminal and Civil Offshore Disclosure Questions.” On the Webinar panel were two IRS officials: David W. Horton, Director, IRS...
OFFSHORE VOLUNTARY DISCLOSURE PROGRAM (OVDP): STRICT APPLICATION OF 50% PENALTY CAN BE HARSH
February 15, 2015
Consider the following fact pattern: Father and daughter are participants in the OVDP who submitted their OVDP Letters after August 4, 2014. Each owned separate unreported offshore bank accounts during the OVDP period...