Igor Drabkin’s article “International Reporting Penalties — What to Expect and How to Fight Them” was published in the January 2015 edition of the CCH Journal of Tax Practice and Procedure.
On January 30, 2014, the Internal Revenue Service updated its list of Foreign Financial Institutions or Facilitators, whose clients meet criteria for a 50% Penalty in the Offshore Voluntary Disclosure Program (OVDP).
Another victory for the government in their fight against hidden offshore accounts was announced today in Los Angeles.
IRS Announces Major Changes to Offshore Voluntary Disclosure Program
In the case of USA v. Carl Zwerner, the jury found that willful FBAR penalties of 50% of the account value applied to multiple years, thus, making the aggregate FBAR penalty equal to 150% of the account balance.
IRS and Department of Treasury announced that calendar years 2014 and 2015 will be considered as a transition period for purposes of IRS enforcement and administration with respect to the implementation of the Foreign Account Tax Compliance Act (FATCA)