Search Results for: streamline
New IRS internal procedure guidance for Streamline Filing Compliance Procedures
…receiving follow up inquires from the IRS for some of our streamlined program filers. The streamlined program offers a good option for many taxpayers with undeclared accounts. Our firm…
New IRS IRM with Updated Streamlined Filing Compliance procedures
…IRS audits, IRS collections, IRS appeals and criminal investigations. The IRS recently internally changed the IRM for the IRS’ revised “streamlined” procedures for individuals who unintentionally fail to report foreign-source…
Details of the Streamlined Foreign Offshore Procedures (SFOP)
…obligation, there are a number of programs through which they can become compliant. One option, if the taxpayers meet the requirements, is to file under the Streamlined Domestic Offshore Procedures…
Streamlined Filing Compliance Procedure’s New Revisions to Streamlined Foreign Offshore Procedures (SFOP)
…file under the Streamlined Domestic Offshore Procedures (SDOP) or the Streamlined Foreign Offshore Procedures (SFOP). This article focuses on the SFOP. The Internal Revenue Service (IRS) recently modified the non-willfulness…
IRS Streamlines its Streamlined Offshore Procedures with More User Friendly Forms
…below: Form 14653–Certification by U.S. Persons Residing Outside of the United States for Streamlined Foreign Offshore Procedures Form 14654–Certification by U.S. Persons Residing in the United States for Streamlined Domestic…
New IRS procedures for Streamlined Filing Compliance Procedures for 2017 transition tax filers
…apply to Streamlined Domestic Offshore submissions and Streamlined Foreign Offshore submissions. The new procedures are pasted below with my comments added in italics. The “transition tax” per section 965 of…
New IRS guidance Announced for IRS Streamlined Offshore Procedures.
…file under the Streamlined Domestic Offshore Procedures (SDOP) or the Streamlined Foreign Offshore Procedures (SFOP). Our firm has recently received many inquiries regarding these new IRS Streamlined Offshore Procedures. These…
IRS Official Provides Insights for the new IRS Streamlined Compliance Procedures
…and Delinquent International Information Return Submission Procedures. Our firm presented an informational webinar on the Streamlined Filing Compliance Procedures. Materials from the webinar can be downloaded here: Game Changer Streamline….
Taxpayer’s Beware: Proving Non-Willful Conduct in the new IRS Streamlined Filing Compliance Procedures
…that the IRS will carefully monitor taxpayer filings with large accounts making fraudulent claims in the streamlined program and punish them severely to send a warning. While the streamlined program…
A solution in a tough tax season: the IRS Streamlined Offshore Procedures
…file under the Streamlined Domestic Offshore Procedures (SDOP) or the Streamlined Foreign Offshore Procedures (SFOP). Our firm has recently received many inquiries regarding these new IRS Streamlined Offshore Procedures. These…
IRS announces new Streamlined Filing Compliance Procedures
…reside outside the U.S. ($0 penalty) Streamlined procedures for U.S. residents are referred to as the Streamlined Domestic Offshore Procedures (SDOP). This program is for U.S. citizens or permanent residents…
New Streamlined Domestic Offshore Procedures (SDOP) is a Game Changer
…to determine possible alternatives to electronic filing. Our firm presented an informational webinar on the Streamlined Filing Compliance Procedures. Materials from the webinar can be downloaded here: Game Changer Streamline….
New IRS Disclosure Program Announced for Non-Resident Taxpayers: Streamlined Foreign Offshore Procedures
…use the Streamlined Domestic Offshore Procedures (SDOP)) taxpayers alike. The SFOP significantly expands the old Streamlined Program for Non US-residents, which was narrowly only for non-filers with less than $1500…
Streamlined Filing Compliance Procedure’s New Revisions to Streamlined Domestic Offshore Procedures (SDOP)
…file under the Streamlined Domestic Offshore Procedures (SDOP) or the Streamlined Foreign Offshore Procedures (SFOP). This article focuses on the SDOP, which is for taxpayers who reside in the United…
Details of the Streamlined Domestic Offshore Procedures
…experienced tax attorney. Our firm presented an informational webinar on the Streamlined Filing Compliance Procedures. Materials from the webinar can be downloaded here: Game Changer Streamline. Patel Law Offices has…
An Ill-advised IRS Streamlined Filing Compliance Procedure Filing
Yesterday the US Department of Justice announced here the indictment of Mark Anthony Gyetvay, who filed to enter IRS “Streamlined Filing Compliance Procedures in which he attested that his prior…
IRS Clarifies Requirements for Streamlined Filing Procedures
…Our firm recently presented a informational webinar on the Streamlined Filing Compliance Procedures and the Offshore Voluntary Disclosure Program. Materials from the webinar can be downloaded here: Game Changer Streamline….
Avoiding and Defining Willfulness
…by taxpayers in the Streamline program. The Importance of Willfulness Because of their lower penalties and simplified reporting requirements, taxpayers often prefer to participate in Streamlined Disclosure Programs as opposed…
New Report: Delinquent Taxpayers Could be Identified at US Border Crossings
…Streamline Procedures (non-resident SFOP and domestic SDOP). For those taxpayers who do not meet the eligibility requirements of the Streamline Procedures there is the offshore voluntary disclosure program (OVDP 2014)….
NJ Division of Taxation Announces Conferences and Appeals Branch Initiative
…may then exercise their further appeal rights. Ensuring that the Branch has updated information for telephone and e-mail contacts for taxpayers and their representatives is important to streamline this process….
New FBAR Court Case Makes it Easier for Taxpayers to be Deemed Willful
…was “willful”, has been in effect in various iterations since 2009. The OVDP end could suggest that Streamline Filing Compliance Procedures may also come to an end. With the closure…
Taxpayers’ Evidence of Non-Willfulness or Willfulness Factors
…is really non-willful. Unfortunately, the IRS has publicly stated that it will intentionally give no further definition of non-willful conduct for purposes of the Streamline Compliance Programs (SFOP or the…
News from the 2014 Criminal Fraud and Tax Controversy Conference
…charge of the IRS Streamlined program), said that there are differences between the OVDP and Streamlined, particularly noting to Streamlined “requires a certification of non-willfulness, and a false certification could…
Citizenship renunciation fee increases as American expatriates flee FATCA
…be downloaded here: Game Changer Streamline. While the streamlined program offers a welcome option for many taxpayers with undeclared accounts, other ways to address past noncompliance remain viable, including the…
Vatican Signs FATCA Agreement
…under the umbrella of the Offshore Voluntary Disclosure Program (OVDP). Last year, the IRS announced its new streamline program for non-willful taxpayers with lower penalties to make it more appealing…
New IRS FBAR Practice Unit
…the relevant statutes and regulations, it fails to provide methods to correct noncompliance. For some options, see our firm’s prior articles on the IRS DFSP or Streamline Filing Compliance Procedures….
IRS Announces Major New changes to the Offshore Voluntary Disclosure Program
…streamlined procedures to accommodate a wider group of U.S. taxpayers who have unreported foreign financial accounts. The original streamlined procedures announced in 2012 were available only to non-resident, non-filers. Taxpayer…
IRS issues new information document request (IDR) directives
The IRS’ Large Business & International division has issued a series of directives that streamline its information document request (IDR) process by establishing stricter deadlines and requiring the agency to…
Automatic Form 5471 and 5472 Penalties in Spotlight by 2020 National Taxpayer Advocate Report
…first-time abatement for all Chapter 61 penalties, including the IRC §§ 6038 and 6038A penalties, to educate taxpayers and streamline tax administration. RECOMMENDATIONS The National Taxpayer Advocate recommends that the…