ABA COMMENTS ON THE 2014 OFFSHORE VOLUNTARY DISCLOSURE PROGRAM AND THE STREAMLINED PROGRAMS

- By : Parag Patel

…available to such taxpayers include the Offshore Voluntary Disclosure Program (“OVDP”), the Streamlined Domestic Offshore Program (“SDOP”), and the Streamlined Foreign Offshore Program (“SFOP”).   The IRS voluntary disclosure programs…

New IRS Disclosure Program Announced for Non-Resident Taxpayers: Streamlined Foreign Offshore Procedures

- By : Parag Patel

…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…

2018 ABA COMMENTS ON THE OFFSHORE VOLUNTARY DISCLOSURE PROGRAM AND THE STREAMLINED PROGRAMS

- By : Parag Patel

…Request”).1 These Comments address issues related to the Offshore Voluntary Disclosure Program (“OVDP”) and the “Streamlined Filing Compliance Procedures” (“Streamlined procedures”), which consist of the Streamlined Domestic Offshore Procedures (“SDOP”)…

IRS announces new Streamlined Filing Compliance Procedures

- By : Parag Patel

…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…

Specific Steps for Applying to the IRS Streamlined Foreign Offshore Procedures

- By : Parag Patel

…the steps, then your application will be rejected for the streamlined procedures. Step 1: An applicant for the streamlined foreign offshore procedures must first file all delinquent or amended tax…

New IRS procedures for Streamlined Filing Compliance Procedures for 2017 transition tax filers

- By : Parag Patel

…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 Streamlined Domestic Offshore Procedures (SDOP) is a Game Changer

- By : Parag Patel

The IRS has announced a Streamlined Domestic Offshore Procedures (SDOP), which will significantly alter all future voluntary disclosures. The SDOP is a game changer for residents and non-resident (who would…

New IRS guidance Announced for IRS Streamlined Offshore Procedures.

- By : Parag Patel

…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…

New Warnings in the IRS’ Streamlined Filing Compliance Procedures

- By : Parag Patel

The Internal Revenue Service has recently updated the certification forms required to be filed by taxpayers seeking to avail themselves of the Streamlined Filing Compliance Procedures. The streamlined program was…

Streamlined Filing Compliance Procedure’s New Revisions to Streamlined Foreign Offshore Procedures (SFOP)

- By : Parag Patel

…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 Official Provides Insights for the new IRS Streamlined Compliance Procedures

- By : Parag Patel

Taxpayers who are in the Offshore Voluntary Disclosure Program to report their overseas assets can request the favorable penalty structure under newly expanded streamlined compliance procedures without giving up the…

Streamlined Filing Compliance Procedure’s New Revisions to Streamlined Domestic Offshore Procedures (SDOP)

- By : Parag Patel

…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…

A solution in a tough tax season: the IRS Streamlined Offshore Procedures

- By : Parag Patel

…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…

Streamlined Procedures for U.S. Taxpayers Residing In the United States

- By : Parag Patel

…General Eligibility: The modified Streamlined Filing Compliance Procedures are designed for only individual taxpayers, including estates of individual taxpayers. The streamlined procedures are available to both U.S. individual taxpayers residing…

Instructions for New Streamlined Filing Compliance Procedures for Non-Resident, Non-Filer U.S. Taxpayers

- By : Parag Patel

…but not limited to, dual citizens who have not filed U.S. income tax and information returns. Description of the New Streamlined Procedure This streamlined procedure is designed for taxpayers that…

How to Demonstrate Non-Willfulness Under The Streamlined Filing Compliance Procedures

- By : Parag Patel

…will be waived under the streamlined procedures. For eligible U.S. taxpayers residing in the United States, the only penalty under the streamlined procedures will be a miscellaneous offshore penalty equal…

Solution: Streamlined Domestic Offshore Procedures

- By : Parag Patel

…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 Clarifying FAQs for Streamlined Offshore Compliance Program

- By : Parag Patel

The IRS updated its streamlined offshore compliance program to provide procedures taxpayers residing both inside and outside the United States should use to participate in the program. The streamlined offshore…

New IRS IRM with Updated Streamlined Filing Compliance procedures

- By : Parag Patel

…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…

Recent Court Decision Shows Risks of IRS Streamlined Filing Compliance Procedures

- By : Parag Patel

A recent court decision from the United States Court of Federal Claims shows the impact of a poorly advised Streamlined Filing Compliance Procedures (Streamlined Program or SFCP) submission. See Flint…

Details of the Streamlined Foreign Offshore Procedures (SFOP)

- By : Parag Patel

…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…

Details of the Streamlined Domestic Offshore Procedures

- By : Parag Patel

…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…

An Ill-advised IRS Streamlined Filing Compliance Procedure Filing

- By : Parag Patel

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…

Taxpayer’s Beware: Proving Non-Willful Conduct in the new IRS Streamlined Filing Compliance Procedures

- By : Parag Patel

…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…

New Comments of the IRS’ New Streamlined Filing Compliance Procedures for Non-Resident Non-Filer U.S. Taxpayers

- By : Parag Patel

…Applying Under Streamlined Procedures. Below are some of my notes: – Taxpayers who do not necessarily meet all the factors under the IRS’s streamlined filing compliance procedures for previously unreported…

IRS Streamlines its Streamlined Offshore Procedures with More User Friendly Forms

- By : Parag Patel

…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…

IRS Clarifies Requirements for Streamlined Filing Procedures

- By : Parag Patel

Our office has received many inquiries from taxpayers interested in the Streamlined Filing Compliance Procedures with the new lower penalty. However IRS guidance and instructions was unclear and ambiguous in…

Happy Birthday Streamlined Filing Compliance Procedure

- By : Parag Patel

…the disclosure of foreign assets. SFCP has two sub-programs: one for US residents (Streamlined Domestic Offshore Procedures or “SDOP”) and one for non-US residents (Streamlined Foreign Offshore Procedures or “SFOP”)….

IRS Streamlined Filing Compliance Procedures Seminar

- By : Parag Patel

…The expanded streamlined procedures are intended for U.S. taxpayers whose failure to disclose their offshore assets are non-willful. The streamlined filing compliance procedures are available to taxpayers certifying that their…

Consequences of Filing False Streamlined Filings

- By : Parag Patel

…three years in prison. These cases show that taxpayers should be very careful in making a complete and correct Streamlined disclosure to the IRS. Advisors counseling taxpayers on Streamlined Procedures…