TAXLITIGATOR Blog

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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PROTECTING PRIVILEGES DURING AN IRS EXAMINATION

A better-equipped IRS has been able to ferret out potentially sensitive issues in a manner often compromising the relationship between a taxpayer and his own tax representative. If there are potentially sensitive issues, the taxpayer should be interviewed by counsel to determine whether there is a need to fully preserve potentially privileged information. In turn, […] Read More…

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IRS PROTECTIVE CLAIMS FOR REFUND by EDWARD M. ROBBINS, Jr.

If the resolution of a tax refund claim is contingent on future events and may not be determinable until after the time period for filing a claim for refund expires, practitioners can file a protective claim for refund on behalf of the taxpayer. A protective claim can be either a formal claim or an amended […] Read More…

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ERRONEOUS REFUNDS AND CREDITS by Edward M. Robbins, Jr.

If the Internal Revenue Service makes an error in issuing a refund, it can recover the amount incorrectly refunded by filing a suit for erroneous refund. Section 7405[1] provides the Service with the ability to recover erroneous refunds within two years of payment. The two-year period can be extended to five years if any part […] Read More…

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U.S. Seeks FBAR Related Forfeiture of $12 Million

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 […] Read More…

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JUST RELEASED: Hot Audit Issues for the California FTB !!

The California Franchise Tax Board (FTB) just released the list of “hot” audit issues they are encountering in the process of examining returns filed by California taxpayers. The FTB is responsible for administering two of California’s major tax programs: Personal Income Tax (PIT) and the Corporation Tax. The FTB regularly receives and processes more than […] Read More…

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Virtual Currency Constitutes Taxable Property for U.S. Federal Tax Purposes

The IRS recently released guidance on the U.S. federal tax implications of transactions in, or transactions that use, virtual currency, such as Bitcoin.[1] For tax purposes, “gross income” is defined as “all income from whatever source derived”, including interest income, gains from dealings in property, and compensation paid for services, whether furnished by the taxpayer […] Read More…

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