
IRS Issues Proposed Regulations for the Foreign Account Tax Compliance Act (FATCA)
IRS Issues Foreign Account Tax Complianec Act (FATCA) Proposed Regulations
IRS Issues Foreign Account Tax Complianec Act (FATCA) Proposed Regulations
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.
On January 3, 2012, the U.S. Attorney’s Office for the Southern District of New York charged three Swiss bankers with hiding more than $1.2 billion in U.S. taxpayer accounts from the IRS. The announcement was made by Preet Bharar, the Manhattan U.S. Attorney.
IRS has put in place a program aimed at auditing taxpayers who did a so called “quiet disclosure” — those who chose not to make a voluntary disclosure, but rather chose to quietly file amended tax returns and FBARs.