Norris McLaughlin & Marcus, P.A.

Blogs > Business Without Borders


Dec 23, 2014

(VIDEO) Details Behind The Offshore Voluntary Disclosure Program

As an extension and follow-up to the 2012 Offshore Voluntary Disclosure Program, the IRS offers taxpayers reduced penalties with income from offshore accounts. The program offers significant benefits for taxpayers to disclose foreign accounts and avoid the risk of an audit and possible criminal prosecution.

In Part 2 of her video series, Melinda Fellner Bramwit explains the current program options for an Asset-Based Penalty or an Income-Based Penalty.» Read More

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


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