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Last Call: The IRS Will Soon Close the Offshore Voluntary Disclosure Program, Leaving a Limited Window to Obtain Criminal Amnesty

In OVDP by Jason FreemanLeave a Comment

The IRS recently announced that it will officially close the Offshore Voluntary Disclosure Program (“OVDP”) in September of 2018.  Its announcement serves as a “last call” for taxpayers who have willfully failed to report foreign assets or income—a last opportunity to come forward under the terms of the OVDP, which provides for criminal amnestyand other protections.  After September 2018, the …

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The Paradise Papers Continue to Shed Light on the Use of Offshore Tax Havens

In FATCA, FBAR, Offshore Tax, OVDP by Jason Freeman and Spencer BanksLeave a Comment

The Paradise Papers represent the latest large-scale leak of financial documents believed to link thousands of companies and individuals to hidden offshore accounts and secret tax havens.  The leak was massive, totaling some 1,400GB of data—that translates to an estimated 13.4 million documents covering a period from 1950 to 2016.[i]Nearly half of the leaked documents come from corporate registries in …

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Last Call: The Offshore Voluntary Disclosure Program to End

In OVDP by Jason FreemanLeave a Comment

With the IRS recently announcing that it intends to officially close the Offshore Voluntary Disclosure Program (“OVDP”) by September 28, 2018, it has formally issued a “last call” for taxpayers with willful foreign reporting deficiencies.  According to the IRS, the announcement of the coming end to the OVDP “reflects advances in third-party reporting and increased awareness of U.S. taxpayers of …

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An Update on International Tax Enforcement

In Audit, International Tax, Offshore Tax, OVDP by Jason FreemanLeave a Comment

International tax enforcement remains one of the nation’s top tax priorities. Indeed, a number of important developments over the past year signal that offshore enforcement issues remain firmly in the government’s crosshairs. Notably, the past year saw the Treasury Department implement several key regulations that impose new reporting obligations and that are designed to increase transparency and promote its ability …

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Offshore Tax Evasion Remains on IRS “Dirty Dozen” List for 2017

In International Tax, Offshore Tax, OVDP by Jason FreemanLeave a Comment

Every year, the IRS compiles its “Dirty Dozen” list of tax scams/priorities—a list of tax enforcement priorities that the IRS and the Department of Justice work closely to address and, where appropriate, prosecute.  Not surprisingly, offshore tax evasion is once again among the agency’s top enforcement priorities. Offshore tax evasion has been a high priority since the IRS’s rollout of …

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The Swiss Bank Program: The Justice Department Announces Final Resolutions

In International Tax, Offshore Tax, OVDP by Jason FreemanLeave a Comment

The Justice Department recently announced that it has reached final resolutions under the Swiss Bank Program. The Program allowed cooperating Swiss banks to resolve their potential U.S. criminal liabilities and to cooperate in DOJ’s ongoing investigations into the use of foreign bank accounts by U.S. taxpayers to commit tax evasion. The announcement marked the completion of the examination of Category …

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IRS Offshore Compliance: New Stats Indicate a Slow in OVDP Submissions

In International Tax, Offshore Tax, OVDP by Jason FreemanLeave a Comment

The IRS has announced updated statistics for its two primary offshore compliance programs: The Offshore Voluntary Disclosure Program and the Streamlined Filing Compliance Procedures.  And the new data tells an interesting story.  All told, some 55,800 taxpayers have now come into the OVDP, paying in more than $9.9 billion in taxes, interest and penalties since the 2009 version of the …

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The Brazilian Tax Amnesty Program: The Regime Especial de Regularização Cambial e Tributária

In OVDP by Jason FreemanLeave a Comment

Earlier this year, the Brazilian government put into place the Special Currency and Tax Regularization Regime (Regime Especial de Regularização Cambial e Tributária or “RERCT”), a fiscal amnesty program established by Law No. 13,254/2016 that allows holders of previously undeclared offshore assets to report those assets to Brazilian tax authorities.  The program is currently set to close on October 31, …

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Government Report Finds that Improvements are Needed in the Offshore Voluntary Disclosure Program

In International Tax, Offshore Tax, OVDP by Jason FreemanLeave a Comment

TIGTA initiated an audit to assess how well the IRS is managing the OVDP.  TIGTA specifically looked into the IRS’s efforts to improve taxpayer compliance and to hold accountable taxpayers who fail to report their offshore financial activities on their tax returns or on a Report of Foreign Bank and Financial Accounts (FBAR).  In a report released this summer, TIGTA …