In earlier blog posts I have discussed how Streamlined Filings differ from OVDP submissions. One major difference: unlike an OVDP submission, a taxpayer making a Streamlined Filing is not informed upfront whether his or her...
Category: FBARS
SOME FBAR GOOD NEWS AND MORE OVDP BAD NEWS
August 6, 2015
FBAR FILING DATE CHANGED TO APRIL 15 It is rare but occasionally congress enacts a law that makes eminent good sense. Tucked away in the Highway Funding Bill (HR 3236) signed by President Obama on July 31, 2015 are tax...
After James Moore had filed amended returns and delinquent FBARS, the IRS assessed against him maximum non-willful FBAR penalties of $10,000 for each of the years 2005 through 2008, for a total of $40,000. Instead of...
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...
EVALUATING RISK OF PROSECUTION OUTSIDE OF THE OVDP
December 10, 2014
An article authored by Edward Robbins, Jr. Steven Toscher and Dennis Perez, “What’s Your Client’s Criminal Exposure on His Undeclared Foreign Bank Account? (Journal of Tax Practice, October – November 2012 pp 67-74),...