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Tax Attorney, Michael DeBlis, III, Esq, LLM Explains New IRS Overhaul Of OVDP And Why Voluntary Disclosure Of Offshore Accounts May Save You Thousands In Penalties

DeBlis explains, “Taxpayers with undisclosed foreign accounts or entities should make a voluntary disclosure because it enables them to become compliant, avoid substantial civil penalties, and eliminate the risk of criminal prosecution. Making a voluntary disclosure also provides the opportunity to calculate, with a reasonable degree of certainty, the total cost of resolving all offshore […]

Tax Attorney, Michael DeBlis, III, Esq, LLM Explains New IRS Overhaul Of OVDP And Why Voluntary Disclosure Of Offshore Accounts May Save You Thousands In Penalties

DeBlis explains, “Taxpayers with undisclosed foreign accounts or entities should make a voluntary disclosure because it enables them to become compliant, avoid substantial civil penalties, and eliminate the risk of criminal prosecution. Making a voluntary disclosure also provides the opportunity to calculate, with a reasonable degree of certainty, the total cost of resolving all offshore […]

The Black Market Peso Exchange Explained

For years, compliance officers in the financial centres of the Caribbean have been grappling with money-flows that use the Black Market Peso Exchange, the single most efficient money-laundering system in the Western Hemisphere. Michael DeBlis of the US tax litigation firm of DeBlis & DeBlis examines its origins and modus operandi.

New Streamlined Filing Procedures: A Trap For the Unwary?

I recently attended the NYU’s Tax Controversy Forum.  Two of the panelists were officials from the IRS: Jennifer Best, Senior Advisor, IRS Large Business and International Division, and John McDougal, special trial attorney and division counsel, IRS Small Business and Self-Employed Division. Both offered insight into the newly expanded streamlined filing procedures.  One of the […]

Understanding the Streamlined Filing Compliance Procedures

On Wednesday, June 18, 2014, the IRS overhauled the Offshore Voluntary Disclosure Program while expanding and modifying the streamlined filing procedures in order to accommodate a broader group of U.S. taxpayers.  Major changes to the streamlined procedures include the following: (1) extension of eligibility to U.S. taxpayers residing in the U.S., (2) elimination of the […]

Transitioning From 2012 OVDP to Streamlined Compliance Procedures: Q & A

(1) What is the purpose of transitional treatment under OVDP? Transitional treatment under OVDP allows taxpayers currently participating in OVDP who meet the eligibility requirements for the expanded Streamlined Filing Compliance Procedures announced on June 18, 2014, an opportunity to remain in the OVDP while taking advantage of the favorable penalty structure of the expanded […]

Offshore Account Penalties to Double With Start of 2014 OVDP Program

On Wednesday, June 18, 2014, the IRS announced that it was trying to make it easier for taxpayers to come clean about offshore accounts. The Service made changes to two key programs – one intended for taxpayers that willfully sought to evade tax laws, and another for those that avoided taxes despite trying to comply […]

The Dawn of a New Day For U.S. Citizens With Undisclosed Offshore Accounts

Hold on to your seats!  The IRS just recently announced changes to its offshore voluntary compliance programs and it more than likely will affect you!  The changes that were announced on June 18, 2014 are expected to help both taxpayers living abroad and those living within the United States come into compliance with their U.S. […]

Anatomy of a Criminal Tax Case: From Investigation to Prosecution

The traditional means of developing a criminal tax case is the so-called administrative route.  This article describes administrative cases from four perspectives: (1) origin of the case; (2) investigation by CI; (3) moving the case from CI to DOJ; and (4) case processing by DOJ. I. Origin of the Case ** Traditionally, the largest source […]