The IRS has Announced a New Offshore Voluntary Disclosure Program (1/9/2012)
For the new program, the penalty framework requires individuals to pay a penalty of 27.5 percent of the highest aggregate balance in foreign bank accounts/entities or value of foreign assets during the eight full tax years prior to the disclosure. That is up from 25 percent in the 2011 program. Some taxpayers will be eligible for 5 or 12.5 percent penalties; these remain the same in the new program as in 2011.
Participants must file all original and amended tax returns and include payment for back-taxes and interest for up to eight years as well as paying accuracy-related and/or delinquency penalties.
IRS Softening Treatment of U.S. Citizens Residing Outside The U.S.
The IRS has clarified its positionwith respect to U.S. Citizens or Duel Citizens Residing Outside the U.S. Although the rules have not changed, it seems that the IRS may soften its application of the rules. Time will tell! To review IRS fact sheet FS-2011-13 CLICK HERE.
Undeclared Offshore Accounts
If you have been following the offshore enforcement news on mytaxlaw.com, it is likely that you have an undeclared offshore account or other compliance issues. You may be very concerned with the prospect of facing criminal prosecution and/or significant penalties if your foreign bank discloses your account records to U.S. authorities.
We understand that these concerns can be overwhelming. Many holders of undeclared accounts describe a range of emotions including anxiety, depression, fear, and paranoia. These emotions may cloud your judgment and cause you to make irrational decisions which actually make your compliance issues worse. Account holders should make educated decisions which are not fear based decisions.
Our core belief is that the best decisions are made by the people with the most information. We strive to keep our clients and followers informed by tracking the latest news related to UBS, HSBC, Credit Suisse, Julius Baer, Bank Leumi, Deutsche Bank, and Basler Kantonalbank.
Over 90 percent of our practice is dedicated to offshore compliance issues. We are currently representing numerous clients in the 2011 Offshore Voluntary Disclosure Initiative. We have also represented numerous clients in the three prior offshore disclosure initiatives (OVDP, OVCI, & LLCI). Our attorneys handle a wide variety of cases ranging from very large complex cases to relatively simple small cases.
I would like to personally thank you for visiting mytaxlaw.com and ask that you kindly consider our Firm in your search for an attorney to assist you with your offshore compliance matter.
Offshore Voluntary Disclosures
Although most of the news agencies erroneously report that the 2011 OVDI is the second offshore amnesty program offered by the IRS, it is actually the fourth offshore amnesty program. The first program occurred in 2003 and was known as the Offshore Voluntary Compliance Initiative (OVCI) and only had approximately 1,500 participants (Teig represented multiple clients in this program). The second program evolved from the from first program and was known as the Last Chance Compliance Initiative (LCCI). The third program was known as the 2009 Offshore Voluntary Disclosure Program (2009 OVDP). Teig has successfully represented clients in every offshore voluntary disclosure program offered by the IRS.
Call 305-576-4242 to speak with Teig Lawrence regarding your Offshore Account.
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