Rescued From The Brink of Insanity: OVDP and Double Counting
What is this phenomenon known as double counting? Why is it important? If you are shepherding clients through the OVDP program (or through streamlined domestic), or you are going through the program yourself, it is critical that you understand what it means and the governing principles behind it. Otherwise, you could be paying an offshore […]
On the Brink of Insanity: How to Calculate the Miscellaneous Offshore Penalty under the Streamlined Domestic Procedures
Instructions for Making a Streamlined Domestic Offshore Submission [Podcast]
A Logical Program Made Unnecessarily Complicated: The IRS’ Approach to International Information Returns
I wish to graciously acknowledge the work of Phillip J. Colasanto, Esq. from the law firm of Agostino & Associates, P.C. whose keen insight and innovative thinking as reflected in his article entitled, “The International Information Reporting Penalties: Is the IRS’s Failure to Embrace a One-Stop Shopping Paradigm Inefficient and Statutorily Deficient?,” has proven invaluable. His guidance […]
The Changing State of Voluntary Disclosure
A new year brings with it many things, including, of course, news and updates from the IRS. As tax year 2019 draws closer, it’s time to start thinking about the many changes to come, like the IRS’ recently published updates to the 2018 OVDP and Voluntary Disclosure rules. As with most situations regarding the IRS, nothing stays […]
Demystifying the FBAR – A Webinar
This is a webinar that I presented in partnership with CPA Academy. I’m honored to lecture for such a fine CPE provider. For those who are interested in obtaining CPE credit, click here to sign up. Below is more information about the program: Course Description This course breaks the FBAR down into its individual components and […]
New Willful FBAR Case is Eerily Foreboding for Taxpayer
A new willful FBAR penalty case is getting way in the Southern District of New York. And from the looks of it, the taxpayer appears to have an uphill battle. In United States v. Gentges (USDC SDNY Dkt. 7:18-cv-07910), the Government filed suit to collect a “willful” FBAR penalty from a New York resident for a single […]
A Quick Primer on Form 5471 and Some Hidden Pitfalls to Avoid
Form 5471 is triggered in situations where a “U.S. Person” owns an interest in a “foreign” (non-U.S.) corporation. The specific reporting requirements for Form 5471 are found in Internal Revenue Code Sections 6038 and 6046. Broadly speaking, the purpose of Form 5471 is to identify “U.S. Persons” who: own at least 10% of a “non-U.S.” […]
OVDP Sunsetting on September 28 – New Procedures On The Horizon
On September 4, 2018, the Internal Revenue Service (IRS) reminded taxpayers that they have until September 28, 2018 to apply for the Offshore Voluntary Disclosure Program (OVDP). Back in March, the IRS announced that it would be discontinuing the program on September 28, 2018. This does not mean that the IRS is going to discontinue pursuing taxpayers […]
Failing to File an FBAR Can Mean Big Fines and Big Penalties
There’s no denying the will of the government. In the U.S., what the government says effectively goes, and if you don’t like it – well, that’s too bad. And nowhere is this truer than it is in the case of willful FBAR penalties. Imposed as a way to enforce foreign account reporting for American citizens both domestic and […]