By Jonathan Prokup and Dustin Covello Following the release of Ann and Mitt Romney’s tax returns, the news media and political commentators of all stripes have – to paraphrase Arlo Guthrie – detected, neglected, selected, rejected, and inspected those returns for a variety of commercial and political purposes. As expected, the return shows substantial income, [...]
Posted tagged ‘OVDI’
« Tax Blawg home page
The Romneys’ Tax Returns: Have FBARs Been Filed, Or Is Romney An OVDI “Candidate”?
January 25, 2012Categories: Administrative, Individual, International
Tags: FBAR, foreign investment, Mitt Romney, offshore bank accounts, OVDI, Penalties, PFIC
Comments: 1 Comment
Fox Business Interview: OVDI, FBARs, And The Economic Benefits Of A Repatriation Holiday
January 17, 2012By Jonathan Prokup Fox Business invited me to appear yesterday on “After The Bell” with Liz Claman and David Asman to discuss (i) the IRS reopening the disclosure initiative for offshore bank accounts and (ii) the ongoing debate about whether Congress should implement a corporate repatriation holiday. A link to the video is below the [...]
Categories: Administrative, International
Tags: FBAR, IRS, job creation, offshore bank accounts, OVDI, repatriation, stimulus, Taxes
Comments: 1 Comment
IRS Reopens Offshore Voluntary Disclosure Initiative (OVDI) For Delinquent FBAR Filers: 27.5 Percent Penalty
January 10, 2012By Jonathan Prokup and Dustin Covello The IRS announced yesterday a reopening of its 2011 offshore voluntary disclosure initiative (“OVDI”). This program will have essentially the same terms as the 2011 OVDI, but with a penalty rate of 27.5 percent (rather than 25 percent) of the highest account balance during the period covered by the [...]
Categories: Administrative, Individual, International
Tags: Credit Suisse, FBAR, HSBC, offshoare bank accounts, OVDI, Penalties, Swiss, tax evasion
Comments: Be the first to comment
Good News For Bank Account Disclosures By U.S. Citizens Residing In Canada
December 5, 2011By Jonathan Prokup Over the weekend, a variety of Canadian news sources (see, e.g., the Financial Post and the Edmonton Journal) reported on anticipated guidance from the IRS, which would result in the waiver of penalties on certain U.S. citizens living in Canada for past failures to file Form TD F 90-22.1, commonly known as [...]
Categories: Administrative, Individual, International
Tags: bank accounts, Canada, disclosure, FBAR, IRS, OVDI
Comments: Be the first to comment
After OVDI: What’s Next For Disclosures Of Foreign Bank Accounts?
December 2, 2011By Jonathan Prokup For taxpayers who entered the IRS’s second Offshore Voluntary Disclosure Initiative (“OVDI”) prior to August 31, 2011, November 29th marked the end of the extended deadline that some taxpayers requested for submitting all of the materials included in the disclosure (e.g., amended returns, FBARs). Coincidentally with the timing of this deadline, many [...]
Categories: Administrative, Corporate, Individual, International
Tags: bank account, FBAR, IRS, noisy disclosure, OVDI, Penalties, quiet disclosure
Comments: 2 Comments
Going Quietly Into The Night May Not Be The Best Idea For U.S. Citizens Living Abroad
August 26, 2011Apparently, there are a large number of U.S. citizens living outside the United States as well as a large number of individuals who are dual citizens of the United States and their country of residence (estimated to be in the millions). Judging from the phone calls that I have been receiving from my contacts at foreign [...]
Categories: Administrative, International
Tags: FBAR, foreign bank accounts, OVDI, tax evasion
Comments: Be the first to comment
FBAR Penalties: The IRS Lays Down The Law On Quiet Disclosures
May 23, 2011By Jonathan Prokup As part of its current Offshore Voluntary Disclosure Initiative (“OVDI”), the IRS is strongly encouraging taxpayers against making so-called “quiet” disclosures, in which taxpayers file amended tax returns, pay the applicable taxes and interest, and hope that the IRS doesn’t identify them for further investigation. These disclosures are described as quiet because [...]
Categories: Corporate, Individual, International
Tags: bank accounts, HSBC, offshore, OVDI, Penalties
Comments: Be the first to comment
Alphabet Soup: HSBC, FBAR, And OVDI (Offshore Voluntary Disclosure Initiative) For Foreign Bank Accounts
April 14, 2011By Jonathan Prokup Last week, the United States Department of Justice asked a federal court in San Francisco to force HSBC India to disclose the names of U.S. customers whom the Justice Department suspects are evading U.S. tax laws. According to the Justice Department’s brief, HSBC India solicited U.S. residents of Indian origin to open [...]
Categories: Administrative, Corporate, Individual, International
Tags: FBAR, foreign bank accounts, HSBC, India, OVDI, Penalties
Comments: 1 Comment
_______________
Phil Karter
Jonathan Prokup
David Shakow
George Connelly, Jr.
Buck Buchanan
David Bernard
Dustin Covello
Heather Pesikoff
Hale Sheppard
