Blogs > Business Without Borders


Sep 18, 2014

Offshore Voluntary Disclosure Update: Opt-out Appeals Are Possible

As stated in our previous post on June 19, 2014, there are several options available to the taxpayer in the United States and abroad to come forward and report US income and file the appropriate informational returns such as FBARs, Forms 3520 and others.  For a taxpayer who decides to enter the Offshore Voluntary Disclosure Program (“OVDP”), there is currently an asset-based penalty of 27.5% of the highest aggregate balance of the assets in the applicable eight-year period, as well as an income-based penalty imposed on the unreported income. » Read More

Apr 24, 2014

The IRS Offshore Voluntary Disclosure Program Continues

It has been more than two years since the IRS launched the third official offshore voluntary disclosure program (“2012 OVDP”.) In its current form, 2012 OVDP has no set closing date. It is meant to bring U.S. taxpayers into compliance by offering them a fitted approach to filing informational returns and amending their tax returns for unreported offshore income without criminal proceedings.» Read More

Feb 28, 2014

Has the IRS Found Its OVDP Mojo, Just like Austin Powers?


For some time now, the IRS has been focusing on offshore income and offshore assets. Since 2009, the IRS has had three different offshore voluntary disclosure initiatives, designed to offer amnesty to non-compliant U.S. taxpayers who would like to come forward to straighten out the federal income tax situation and their informational filing situation (commonly FBARs).» Read More

Mar 22, 2013

Guidance for Streamlined Filing Compliance Procedures for Non-Resident, Non-Filer Taxpayers

We previously wrote a blog post on the program the IRS launched in September of 2012 for certain taxpayers with offshore income who might qualify for a program which is an alternative to the Offshore Voluntary Disclosure Program. On February 27, 2013, the IRS issued an informative publication giving guidance on issues taxpayers considering entering the program for non-resident, non-filers should consider.» Read More