The recently enacted 2017 tax act (originally called the Tax Cuts and Jobs Act – “Tax Reform Act”) contains sweeping changes to US international tax rules that will affect international businesses and cross border investments. A review of how to take advantage of these new rules can reap significant benefits or avoid tax pitfalls, as
International Tax
Significant Revisions to the IRS Offshore Voluntary Disclosure Program
On June 18, 2014, the IRS announced a revamped Offshore Voluntary Disclosure Program.
The existing OVDP has been in place since March 2009. The program allows a taxpayer to voluntarily come into compliance with US tax reporting obligations and pay a reduced civil penalty rather than facing either greater civil penalty exposure or criminal exposure. …
Mandatory Electronic Filing for FBARs Effective July 1, 2013.
By Geoffrey N. Weinstein on
Posted in International Tax and Planning
June 30, 2013 is the filing due date for 2012 “FBARs,” also known as Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts. If there is a non-willful failure to file, the penalties are up to $10,000. If there is a willful failure to file, the penalties are up to the greater of…
New IRS Guidance in the 2011 IRS Offshore Voluntary Disclosure Initiative
By Jeffrey H. Schechter on
Posted in International Tax and Planning
In February 2011 the IRS announced the Offshore Voluntary Disclosure Initiative (OVDI) for taxpayers with undisclosed foreign accounts. This program was a follow up to a program initiated by the IRS in 2009 on the same topic following civil and criminal cases brought by the Department of Justice against Swiss bank UBS AG seeking the…