Why is the IRS OVDP or Offshore Voluntary Disclosure Program the safest choice for US taxpayers coming into compliance with IRS FBAR disclosures? How does the OVDP reduce risk for US citizens and foreign resident nationals who are required to file US tax returns? The key issue is the IRS'...
Court Dismisses Case Against $1.4M IRS Offshore Penalty
A Texas court has dismissed a lawsuit against the IRS asserting that the IRS burden of proof to assess a $1.4M IRS offshore penalty had not been met. The IRS originally asserted that the plaintiff's failure to file an FBAR for his offshore accounts, assets and investments in 2008 was...
How Has the IRS FBAR Definition of “Non-Willful” Changed?
Why has the IRS questioned or outright rejected many of the applications under the Streamlined Domestic Offshore procedures? How has the IRS FBAR definition of "non-willful" changed? Previously the forms associated with the streamlined domestic offshore procedures (IRS Forms 14653 and 14654) simply asked the taxpayer to "provide specific reasons...