Another Taxpayer Found Guilty of Failure to File FBARs and Report Foreign Income

- By : Parag Patel

…it’s tax fraud. We are continuing our work to crack down on offshore tax evasion.” A timely filed OVDP submission (or maybe SDOP filing) may have saved Mr. Mukhi. Stay…

Opting Out of the Offshore Voluntary Compliance Initiative Programs

- By : Parag Patel

…for a potential audit and imposition of appropriate penalties. The 2012 OVDP program continues the procedures announced in 2011 regarding decisions to “opt out” of the voluntary disclosure penalty structure….

IRS Releases FAQs for the Delinquent International Information Return Submission Procedures

- By : Parag Patel

…for the delinquency. Taxpayers who have unreported income or unpaid tax are not precluded from filing delinquent international information returns. (emphasis added) Unlike the procedures described in OVDP FAQ 18,…

Another Customer with Unreported Offshore Bank Accounts Pleads Guilty

- By : Parag Patel

…decide to keep their foreign assets concealed and of those who advise and assist them serve as clear warnings to anyone who doubts the U.S. government’s resolve.” A timely OVDP

Finally. Government Accountability Office makes recommendations to the IRS for tax laws education to immigrants

- By : Parag Patel

…review, we [GAO] found examples of immigrants who stated in their 2009 OVDP applications that they were unaware of their FBAR filing requirements. We found they had often opened banks…

Another Local New Jersey client of HSBC India Pleads Guilty

- By : Parag Patel

…including two dozen offshore bankers, lawyers and advisers. Several HSBC clients were charged. More than 38,000 Americans avoided prosecution by entering the IRS amnesty program (OVDI/OVDP) in which they paid…

HSBC Bank Expects Significant Penalties from US Government for Violations

- By : Parag Patel

…by entering the IRS amnesty program (OVDI/OVDP) in which they paid back taxes and penalties while disclosing the banks and bankers who helped them hide offshore accounts. Patel Law Offices…

2011 Offshore Voluntary Disclosure Initiative (OVDI)

- By : Parag Patel

…terms of the 2009 Offshore Voluntary Disclosure Program (OVDP). In general, taxpayers will pay taxes for eight years and will pay an offshore penalty of 25% of the highest aggregate…

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

- By : Parag Patel

…the OVDP program and Delinquent FBAR Submission Procedures and Delinquent International Information Return Submission Procedures. The analysis to enter the one program versus other alternative options is complex and requires…

For the First Time IRS Issues Information on 2011 Offshore Voluntary Disclosure Initiative (OVDI) in Hindi Language

- By : Parag Patel

…िजसे 2011 ओफशोर वॉलंटरी िडसक्लोजर इिनशेिटव (OVDI) नाम िदया गया है – में 2009 ओफशोर वॉलंटरी िडसक्लोजर ूोमाम (OVDP) की तुलना में कई बदलाव शािमल िकये गये हैं। 2011 के…

COURT AUTHORIZES SERVICE OF JOHN DOE SUMMONS SEEKING THE IDENTITIES OF U.S. TAXPAYERS WITH OFFSHORE ACCOUNTS AT CIBC FIRSTCARIBBEAN INTERNATIONAL BANK

- By : Parag Patel

…HSBC India accountholders seriously consider entering the IRS OVDP program for protection against civil (and criminal) penalties. Patel Law Offices is a law firm dedicated to helping clients resolve complicated…

IRS Offshore Voluntary Disclosure Programs Continue to Burden “Benign Actors” and Damage IRS Credibility

- By : Parag Patel

…IRS has reportedly revoked pre-clearance letters authorizing taxpayers to participate in the OVDP, even though some had already made disclosures, filed returns, and paid taxes and penalties in reliance on…

Happy Birthday Streamlined Filing Compliance Procedure!

- By : Parag Patel

…lack of understanding or knowledge of reporting requirements for U.S. persons. Unlike the larger exhaustive Offshore Voluntary Disclosure Program (“OVDP”), the SFCP requires that the taxpayer comprehensively asserts that their…

Frequent Scenarios in Offshore Voluntary Disclosures

- By : Parag Patel

I have frequently seen the following scenarios in working with clients to determine whether a offshore voluntary disclosure program filing (OVDP) is appropriate and how they should report foreign account….

IRS Announces New Rules for FBAR Penalties

- By : Parag Patel

…Programs (OVDP), the continued viability of the IRM FBAR mitigation guidelines has been subject to question. It should not be overlooked that the October 28, 2013 revisions to IRM 8.11.6…

Upcoming live video webinar: “FBAR and U.S. Tax Reporting: Compliance Requirements for Foreign Assets”

- By : Parag Patel

…return program IRS disclosure programs U.S. resident Non-U.S. resident Other available options post-OVDP Current IRS procedures for evaluating voluntary submittals Benefits: The panel will review these and other priority issues:…

Argue for No Penalty and a Warning Letter for FBAR Violations

- By : Parag Patel

…of knowledge, education and sophistication. Through the OVDP, our client has also filed all delinquent FBARs. Therefore, in some cases, the issuance of FBAR warning letter 3800, rather than the…

Opting-out or Opting-in of OVDI

- By : Parag Patel

…Out and Removal Guide for the 2009 OVDP and 2011 OVDI where the procedures for opting out are set forth. The revised FAQs offer helpful guidance on the opt-out option….

IRS Collects $10 Billion From Voluntary Disclosures of Foreign Assets

- By : Parag Patel

…Program, or OVDP, allows taxpayers who have undisclosed income from foreign financial accounts and assets the chance to catch up with their tax filings and information reporting obligations. Taxpayers can…

New IRS IRM with Updated Streamlined Filing Compliance procedures

- By : Parag Patel

…income or foreign assets, generally, foreign bank accounts. In part, the revised procedures address concerns of taxpayers and their professional advisers that the traditional offshore voluntary disclosure programs (OVDPs) often…

New Report: Delinquent Taxpayers Could be Identified at US Border Crossings

- By : Parag Patel

…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)….

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

- By : Parag Patel

…major difference from OVDp treatment of the same assets. A participating taxpayer will be subject only to the 5-percent miscellaneous offshore penalty and will not be subject to accuracy-related penalties,…

IRS Passport Revocation or Denial for Unpaid Taxes

- By : Parag Patel

…Procedures (SFCP) or Offshore Voluntary Disclosure Program (OVDP). Contact our law office to learn more. To learn more and book a free strategy session please see our dedicated website: https://www.irsrevokedpassport.com/…

50% Penalty for Taxpayers Who Hold Accounts at a Bank Under Investigation

- By : Parag Patel

…amnesty program who intended to cheat. For taxpayers who enter the OVDP program after it becomes public that a bank where the taxpayer holds an account is under investigation by…

Cayman Islands Advisors Arrest Suggest U.S. Government Receiving More Information About Offshore Accounts

- By : Parag Patel

…result of this probe. Taxpayers are ineligible to participate in the IRS’s offshore voluntary disclosure program (OVDP) for undeclared offshore accounts if U.S. authorities already have their names. The program…

New IRS Form 8938 Statement of Foreign Financial Assets is causing significant confusion

- By : Parag Patel

…be reported on Form 8938 that are not required to be reported on Form 90-22.1. Form 8938 May Force Taxpayers to Enter the Offshore Voluntary Disclosure Program (OVDP) This ability…

The New IRS Voluntary Disclosure Practice: Not a Good Deal for Noncompliant Taxpayers

- By : Parag Patel

…the old Offshore Voluntary Disclosure Program (OVDP), taxpayers do not receive automatic protection against criminal/civil penalties and the IRS has wide discretion to impose penalties based on the taxpayer’s level…

Checklist of tax forms for taxpayers with foreign assets

- By : Parag Patel

…of offshore assets. Taxpayers should explore the OVDP program to avoid criminal prosecutions and civil audit examinations. Patel Law Offices is a law firm dedicated to helping clients resolve complicated…

Details of the Streamlined Foreign Offshore Procedures (SFOP)

- By : Parag Patel

…ways to address past noncompliance remain viable, including the OVDP program and Delinquent FBAR Submission Procedures and Delinquent International Information Return Submission Procedures. The analysis to enter the one program…

OVDI: Requesting issuance of a FBAR warning letter instead of penalties

- By : Parag Patel

…unexpected (and the worst) in their tax treatment and disclosure of offshore assets. Taxpayers, who have not done so already, should explore the OVDP program to avoid criminal prosecutions and…