The National Taxpayer Advocate (NTA) has issued a Taxpayer Advocate Directive , complaining about unfair treatment of certain participants in the 2009 Offshore Voluntary Disclosure Program (OVDP). It appears that the NTA shared the same frustration with the OVDP that many tax practitioners, including our tax attorneys, have felt over the infamous Q&A 35 published by the IRS in the Frequently Asked Questions and Answers for the 2009 program.

Today, the IRS announced that they reopened the Offshore Voluntary Disclosure Program for taxpayers with undeclared foreign accounts.

The IRS is reminding taxpayers that the deadline for the 2011 Offshore Voluntary Disclosure Initiative (OVDI) will expire on August 31, 2011.

The Department of Justice and the Internal Revenue Service (IRS) announced on June 28, 2011, that Dr. Arvind Ahuja of Wisconsin was indicted on four counts of willfully filing materially false tax returns and four counts of failing to file Reports of Foreign Bank and Financial Accounts (FBARs).

Indian-Americans seek review of FBAR rules and the IRS’ 2011 Offshore Voluntary Disclosure Initiative.

On Tuesday, February 8, 2011, the Internal Revenue Service announced a new amnesty program for taxpayers with hidden offshore bank accounts. The new Voluntary Disclosure Initiative is intended to bring people with unreported offshore income and undisclosed offshore accounts back into compliance.

On March 31, 2010, the U.S. and Switzerland signed a protocol to the 2009 agreement that called on Switzerland to provide administrative assistance under Article 26 (Exchange of information) of the Switzerland-U.S. income tax treaty regarding information on the U.S. clients of UBS (UBS Agreement). Although the terms of the protocol were not provided to the public, the Swiss Federal Council said that the revised UBS Agreement created the necessary legal basis for the Switzerland’s tax administration to issue final decisions on “cases regarding continued and serious tax evasion” and permitted Switzerland to comply with its obligations to the U.S. as required under international law.

Los Angeles Tax Attorneys at Holtz, Slavett & Drabkin represent numerous taxpayers in the IRS Offshore Voluntary Disclosure Program.  After the initial information is submitted to the IRS Criminal Investigation Division, a letter is sent from IRS CID stating that the taxpayer has been preliminarily accepted.  The letter further advises that the case will be forwarded for [...]

IRS Extends Deadline for Offshore Accounts Amnesty Program until October 15, 2009

UBS Offshore Account FBAR Update