U.S. Taxpayers at New Risk of Audit from OVDP Declines and Withdrawals Campaign

- By : P. Patel

Last year, the US Treasury Inspector General for Tax Administration (TIGTA) released a report which assessed how well that IRS was managing the Offshore Voluntary Disclosure Program (OVDP). OVDP is one of the programs taxpayers may use to become compliant if they previously had failed to report offshore income on their tax returns and file

IRS Announces new OVDP Declines-Withdrawals Campaign

- By : P. Patel

Earlier this month, the IRS’ Large Business and International division released its list of 13 focus areas for issue- based examinations and concerns for compliance.   One of those areas involves the IRS Offshore Voluntary Disclosure Program.  Entitled, “OVDP Declines-Withdrawals Campaign,” this area of focus involves taxpayers who have applied for the offshore voluntary disclosure

Cost of Compliance Rises under OVDP

- By : P. Patel

The cost of compliance for many people is growing.  Those U.S. persons with bank accounts in foreign jurisdictions who have yet to come into compliance with U.S. tax filing requirements have very little time.  In addition to the increased amount of data being sent to the U.S., last week the US government announced that it

Article Discusses Termination of Offshore Voluntary Disclosure Program (OVDP) and the Streamlined Filing Compliance Procedures (SFCP)

- By : P. Patel

The Internal Revenue Service (IRS) currently offers non-compliant US taxpayers several different relief programs in which to report foreign assets and/or income and become compliant with US rules related to the disclosure of foreign assets. One option is the Offshore Voluntary Disclosure Program (OVDP). Another is the Streamlined Filing Compliance Procedures (SFCP). SFCP is further

File a Protective Claim for Refund for Possible OVDP Opt Out Cases

- By : P. Patel

In 2009, the IRS had introduced an Offshore Voluntary Disclosure Initiative/Program (OVDI/OVDP). In following years, the program was reintroduced and revised. When it comes to addressing offshore filing deficiencies, several issues exist in connection with the statute of limitations, the nature of the error/omission, and the taxpayer’s intent. Many clients have been receiving conflicting advice

OVDP New Forms Announced by IRS

- By : P. Patel

The IRS has simplified the process of entering the OVDP Program by issuing the following forms: Form 14457 – Offshore Voluntary Disclosure Letter Form 14454 – Offshore Voluntary Disclosure Program Letter Attachment The new forms (the old forms were simple Word documents) will likely standardize the IRS’ review process for OVDP eligibility, guide the IRS examiner in

What Is The Difference Between the SDOP and the Current OVDP program?: Willfulness

- By : P. Patel

What Is The Difference Between the SDOP and the Current OVDP program? The Streamlined Offshore Procedures (SDOP and SFOP) liberalizes the old restrictions and rewards taxpayers that disclose their offshore assets with a lower penalty and a very low tax. Taxpayers will only have to file 3 years of amended income tax returns instead of

New offshore voluntary disclosure program (OVDP) changes expected to be favorable to taxpayers

- By : P. Patel

During Internal Revenue Service (IRS) Commissioner John Koskinen’s remarks at a speech before the United States Council-OECD International Tax Conference in Washington last week, he indicated that the agency is preparing a new offshore voluntary disclosure program (OVDP) that will be easier on “law-abiding” American residents abroad. Koskinen disclosed that, “while the 2012 OVDP and

Offshore Voluntary Disclosure Initiative/Program (OVDI/OVDP) opt-out results and updates

- By : P. Patel

Many of our clients are carefully considering OVDI opt-outs. The opt out option became first available during the 2011 OVDI program, and continues with the current OVDP program. The 2012 OVDP program continues the procedures announced in 2011 regarding decisions to “opt out” of the voluntary disclosure penalty structure. In such a case, IRS agents are instructed to neither

New Taxpayer Advocate Service Report Discusses Optouts out of the OVDI/OVDP

- By : P. Patel

The Taxpayer Advocate Service (TAS) has issued a new mid-year 2013 report.  The TAS report discussion regarding optouts out of the OVDI/OVDP is interesting. For the 2009 OVDP (which was a smaller group of applications compared to 2011 OVDI), there were 290 optouts (vs. 10,735 cases closed after certification, or about 3% opted out) taking