IRS Has New Procedures for Scrutinizing Quiet Disclosures

- By : P. Patel

A Quiet Disclosure occurs when a person intentionally files tax returns (either amended or original returns, FBARs, and/or other International Informational Returns) outside of one of the IRS’ formal voluntary disclosure In other words, the individual submits the returns and

Significant FBAR Penalties Upheld by Court

- By : P. Patel

Taxpayers have lost and the US Internal Revenue Service has scored a victory over the taxpayer in Kimble v USA, a court case concerning the reporting of foreign bank accounts. The taxpayer, Alice Kimble, held Swiss accounts at both HSBC and UBS in

Analysis: IRS New Disclosure Program

- By : P. Patel

On November 29, 2018, the IRS released a memorandum that addressed the process for all voluntary disclosures following the end of the Offshore Voluntary Disclosure Program (“OVDP”) on September 28, 2018. The new voluntary disclosure procedure provides uniformity to offshore