Defending and Planning Against Taxes – Tax, Estate Planning, Probate and Elder Law Center

New IRS Voluntary Disclosure in 7 Steps

The following are the seven steps of the new updated IRS voluntary disclosure process: A taxpayer will make a voluntary disclosure preclearance request using IRS Form 14457 to IRS Criminal Investigation (CI). Taxpayers can request preclearance via mail or fax.

New Post-OVDP IRS Voluntary Disclosure Procedures Announced

- By : P. Patel

The Internal Revenue Service released new updated procedures for voluntary disclosures since the old Offshore Voluntary Disclosure Program (OVDP) closed on September 28, 2018. Last week, IRS deputy commissioner Kirsten Wielobob issued Interim Guidance Memo LB&I-09-1118-014, Updated Voluntary Disclosure Practice (PDF) on

New Jersey Tax Amnesty program

- By : P. Patel

Today the New Jersey Division of Taxation announced the launch of their Tax Amnesty program. The program is intended to provide individuals and businesses with the opportunity to pay back taxes or file past returns with no penalties and reduced

The IRS can revoke your passport

- By : P. Patel

If you do not pay your taxes, the IRS may revoke your passport. As the National Taxpayer Advocate (NTA) Nina E. Olson has recently pointed out in her blog, when a taxpayer is notified of such pending revocation, that the taxpayer, nor

Federal District Court Holds that FBAR Penalties in Excess of $100,000 is Unlawful

- By : P. Patel

Recently, the U.S. District Court for the Western District of Texas in U.S. v. Colliot, determined that an individual who repeatedly failed to timely file Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts, commonly referred to as an FBAR,

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”).

New FBAR Court Case Makes it Easier for Taxpayers to be Deemed Willful

- By : P. Patel

There is a debate as to the “burden of proof” that must be met by the Internal Revenue Service (IRS) in asserting that an FBAR violation was “willful”. This is significant because those who willfully fail to file the required

Denied access to or withdrew from the IRS Offshore Voluntary Disclosure Program (OVDP)?

- By : P. Patel

This year taxpayers who either were denied access to or withdrew from the IRS Offshore Voluntary Disclosure Program (OVDP) have been receiving Letter 5935 (HERE) from the IRS notifying them that they need to come into compliance with U.S. reporting requirements

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

New Unreported Offshore Assets case: Bad facts leads to bad results

- By : P. Patel

A resident of Connecticut who was originally from Korea has been hit with a record civil penalty of $14M, a six month prison sentence, and a fine of $100,000 for failing to report Swiss bank accounts totaling around $28M, the

New IRS Voluntary Disclosure in 7 Steps

New Post-OVDP IRS Voluntary Disclosure Procedures Announced

New Jersey Tax Amnesty program

The IRS can revoke your passport

Federal District Court Holds that FBAR Penalties in Excess of $100,000 is Unlawful

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

New FBAR Court Case Makes it Easier for Taxpayers to be Deemed Willful

Denied access to or withdrew from the IRS Offshore Voluntary Disclosure Program (OVDP)?

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

New Unreported Offshore Assets case: Bad facts leads to bad results

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