Your Information source for wills, trusts, estate tax minimization,
powers of attorney, living wills, health care directives, special needs trusts,
asset protection, charitable giving, guardianship, succession planning,
retirement and estate administration. |
Yesterday the Internal Revenue Service opened its Offshore Voluntary Disclosure Program (OVDP) to encourage more taxpayers with assets in undeclared foreign bank accounts to come forward. While the OVDP was not expected by most tax lawyers and professionals, it may be welcomed by many of our clients who missed the recently closed 2011 OVDI program. [...]
Form 8938, Statement of Specified Foreign Financial Assets, is a new reporting form. Form 8938 will be used to report certain foreign financial assets as required as part of the Hiring Incentives to Restore Employment Act (HIRE Act), which was signed into law in 2010 by President Obama. Form 8938 is effective for 2011 and [...]
In a fact sheet (IRS FS-2011-13) released last week, the IRS reminded U.S. citizens and dual citizens of the United States and foreign countries who live abroad about U.S. filing requirements, including Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR). No new developments are provided, only reminders of existing laws and [...]
Earlier this month Credit Suisse Group AG, Switzerland’s second-biggest bank, told U.S. clients it is giving confidential client account data to the Swiss tax authorities, who will decide whether to disclose it to the Internal Revenue Service. The U.S. is probing whether Credit Suisse helped Americans evade taxes, and the IRS used a 1996 tax [...]
Under the 2011 OVDI voluntary disclosure program, the penalties for failing to timely file Foreign Bank Account Reports, (FBAR’s) and the penalties for failure to file information returns (such as Controlled Foreign Corporation tax returns) were combined into a single miscellaneous civil penalty. The penalty combined the FBAR penalty which is established under the Bank [...]
Although the OVDI program has expired, a U.S. taxpayer can still make a voluntary disclosure of foreign accounts pursuant to the IRS’s general voluntary disclosure policy. For over 50 years, the IRS has maintained a voluntary disclosure policy, under which taxpayers can disclose, and rectify, any form of tax noncompliance. To make a voluntary disclosure, [...]
When the IRS says “voluntary” it can sound scary. The IRS is unlikely to use this word unless the potential liability is serious. The IRS would much rather have you come forward. If you do, you’re likely to get a much better deal than if you wait for them to find you. Recent examples include [...]
Even though the deadline for the Internal Revenue Service’s 2011 Offshore Voluntary Disclosure Initiative has concluded last week, U.S. taxpayers with undisclosed offshore accounts still have the opportunity to come forward through the IRS’s traditional Voluntary Disclosure program. Like the OVDI, the traditional Voluntary Disclosure program provides taxpayers an opportunity to come forward and potentially [...]
While our law firm is expeditiously filing OVDI applications and extensions for new OVDI applications, the IRS has extended the OVDI deadline to September 9, 2011 because of the potential impact of Hurricane Irene on taxpayers. The IRS’ announcement was published only three hours ago. The IRS had previously given taxpayers until August 31 to [...]