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A CORNUCOPIA OF OVDP TAX FRAUD by EDWARD M. ROBBINS, Jr.

Has this happened to you? You are in your office toiling away in the tax trenches when a colleague down the street who works the offshore cases sends you an e-mail: “I’m sending over an OVDP client. He has a problem and I can’t represent him anymore.” Eventually the client sits in your office and […] Read More…

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HIDDEN RESOURCES: IRS Audit Techniques Guides

Historically, IRS examiners were assigned to audit taxpayers in many different industries. On one day, an examiner audited a grocery store and on the following day the examiner may have audited a computer retailer or a medical doctor. As a result, experience gained in one audit did not significantly enhance the examiner’s experience for purposes […] Read More…

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Am I “Non-Willful” Under the IRS OVDP Streamlined Procedures ?

The IRS recently announced Streamlined Filing Compliance Procedures in an effort to encourage U.S. taxpayers to come into compliance with their reporting and filing requirements associated with varying interests in foreign financial accounts and assets.[i] The streamlined procedures require the filing of original or amended tax returns reporting not only for whatever foreign source income […] Read More…

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IRS Methods of Indirectly Determining Taxable Income

There are various audit and investigative techniques available to corroborate or refute a taxpayer’s claim about their business operations or nature of doing business. IRS audit or investigative techniques for a cash intensive business might include an examiner determining that a large understatement of income could exist based on return information and other sources of […] Read More…

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FIRST TIME ABATE of IRS Penalties

The Internal Revenue Manual (IRM) contains a Penalty Handbook intended to serve as the foundation for addressing the administration of penalties by the IRS. It is the “one source of authority for the administration of penalties. . .”[1] and provides a “fair, consistent, and comprehensive approach to penalty administration.” As such, the IRM is often […] Read More…

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OVDP & Streamlined Procedures: Expect the Unexpected!

The IRS recently announced Streamlined Filing Compliance Procedures in an effort to encourage U.S. taxpayers to come into compliance with their reporting and filing requirements associated with varying interests in foreign financial accounts and assets. The streamlined procedures require the filing of original (for non-residents) or amended (for residents) tax returns. Such tax returns must not […] Read More…

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Critical Links – 2014 OVDP & Streamlined Filing Compliance Procedures

The IRS recently announced an expansion of the streamlined filing compliance procedures announced in 2012 and important modifications to the 2012 Offshore Voluntary Disclosure Program (OVDP). For eligible taxpayers residing outside the U.S., the revised Streamlined Filing Compliance Procedures provide that all penalties will be waived. For eligible taxpayers residing in the U.S., the revised […] Read More…

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IRS OVDP OPT OUT vs. TRANSITION TO THE NEW STREAMLINED PROCEDURES?

The Internal Revenue Service recently announced significant changes in IR-2014-73[i] regarding their offshore voluntary compliance programs, providing new options to help both resident and non-resident U.S. taxpayers whose failure to disclose their offshore financial accounts was non-willful. The expanded 2014 streamlined procedures are available to a wider population of U.S. taxpayers living outside the country and, […] Read More…

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IRS Changes Streamlined OVDP Reducing FBAR Penalty Exposure!

U.S. taxpayers with previously undisclosed interests in foreign financial accounts and assets continue to analyze and seek advice regarding the most appropriate methods of coming into compliance with their U.S. filing and reporting obligations. Many are pursuing participation in the IRS offshore voluntary disclosure program (the OVDP, which began in 2012 – modeled after similar […] Read More…

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IRS Makes Major Changes to Offshore Voluntary Disclosure Program !

The Internal Revenue Service announced major changes in IR-2014-73 regarding their offshore voluntary compliance programs, providing new options to help both taxpayers residing overseas and those residing in the United States. The changes are anticipated to provide thousands of people a new avenue to come into compliance with their U.S. tax obligations. The changes include […] Read More…

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Reminder: 2013 FBAR Filing Due by June 30, 2014

U.S. persons having a financial interest in or signature authority over a foreign financial account, including a bank account, brokerage account, mutual fund, trust, or other type of foreign financial account may be required by the Bank Secrecy Act to report their interest in the account to the IRS by electronically filing by June 30, […] Read More…

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Zwerner: Jury Determines 150% FBAR Penalty Applies – Excessive Fines Clause to the Rescue??

U.S. taxpayers with previously undisclosed interests in foreign financial accounts and assets continue to analyze and seek advice regarding the most appropriate methods of coming into compliance with their U.S. filing and reporting obligations. Many are pursuing participation in the current IRS offshore voluntary disclosure program (the OVDP which began in 2012), modeled after similar […] Read More…

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