Category: OVDP

The Internal Revenue Service recently announced that it is closing its Offshore Voluntary Disclosure Program, effective September 28, 2018. This is a positive development. Proceeding under the OVDP...

Recently, a man called who had first called me in 2015.  When he first called, the man wanted to become compliant with U.S. laws concerning foreign financial accounts. ...

Accountants commonly send an “organizer” to a client with instructions to complete and sign it and return it to the accountant.  The completed organizer then serves as the...

The Internal Revenue Service’s Offshore Voluntary Disclosure Program (“OVDP”) is the most costly and administratively burdensome means of complying with U.S. laws concerning foreign financial accounts.  Very few...

We place clients into compliance with United States laws concerning foreign financial accounts with the least possible work and expense. In a typical case, a taxpayer or taxpayer’s...

U.S. persons are subject to compliance obligations concerning foreign financial accounts under two statutes, the Internal Revenue Code and the Bank Secrecy Act. A prior article explores who...

Many U.S. persons are alarmed upon learning of their reporting obligations with respect to foreign financial accounts.  Those obligations include reporting the accounts and income therefrom on U.S....

             We assist persons in complying with U.S. laws concerning foreign financial accounts. We prepare FinCEN Forms 114 (formerly Form TD F 90-22.1), Report of Foreign Bank and...

Competent counsel should represent U.S. taxpayers who have failed to file FBARs reporting foreign financial accounts, or who have failed to report foreign financial assets or income therefrom...

A client recently received a letter from a Swiss bank “strongly encouraging” the client to enter the Internal Revenue Service (“IRS”) Offshore Voluntary Disclosure Program (“OVDP”).  The letter...

There are two reasons for a taxpayer to enter the IRS’ Offshore Voluntary Disclosure Program (“OVDP”).  First, to avoid a criminal prosecution.  Second, to avoid the draconian civil...