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

- By : P. Patel

We are members of the American Bar Association Section of Taxation, which on May 2, 2018 submitted comments to the IRS on the IRS Offshore Voluntary Disclosure Program (“OVDP”), the Streamlined Domestic Offshore Program (“SDOP”), and the Streamlined Foreign Offshore Program (“SFOP”).

IRS reminds those with foreign assets about U.S. tax obligations

- By : P. Patel

The IRS again reminded taxpayers yesterday about their reporting obligations for foreign assets and income. The reminder again represents the IRS’ targeted enforcement of tax laws for reporting obligations for foreign assets and income. Taxpayers should take notice and become compliant. The

Run to the Door: IRS Terminates Offshore Voluntary Disclosure Program (OVDP) effective September 28, 2018

- By : P. Patel

IRS Issue Number:    IR-2018-52 IRS to end offshore voluntary disclosure program; Taxpayers with undisclosed foreign assets urged to come forward now WASHINGTON – The Internal Revenue Service today announced it will begin to ramp down the 2014 Offshore Voluntary Disclosure Program

FBAR statute of limitations court case ruling

- By : P. Patel

In its first decision of 2018, the US Tax Court considered whether the six-year statute of limitations in Code Section 6501(e)(1)(A)(ii) applied to a taxpayer who failed to file Foreign Bank Account Reporting, or FBAR forms from 2006 through 2008.

The 65-Day Rule: What Every Trustee Should Know about Taxes

- By : P. Patel

Happy New Year!  With the close of the calendar year behind us, tax season is just beginning for individuals and many entities.  If you are serving as the trustee of a complex trust, however, it’s not too late to take

Some FBAR Deadlines Extended

- By : P. Patel

Last week the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) again extended the deadline for certain financial professionals to file foreign bank accounting reporting forms known as FBARs. In FinCEN Notice 2017-1, FinCEN announced a further extension of time for certain

IRS Advisory: Prepaid Real Property Taxes May Be Deductible in 2017 if Assessed and Paid in 2017

- By : P. Patel

The Internal Revenue Service advised tax professionals  today that pre-paying 2018 state and local real property taxes in 2017 may be tax deductible under certain circumstances. The new tax law signed last week in Washington prohibited the deduction of prepaid