Category: International Taxation

The Internal Revenue Service will be providing new guidelines to the Offshore Voluntary Disclosure Program (OVDP) which address such issues as the number of years at issue (there has been much debate amongst tax attorneys as to whether it is 3, 6, 8, or more). We also expect it to...

The Internal Revenue Service (IRS) announced a recent third Offshore Voluntary Disclosure Program (OVDP) for U.S. taxpayers with unreported foreign income or financial accounts. The OVDP eliminates potential criminal penalties and greatly reduces the civil (monetary) penalties for U.S. taxpayers with previously undisclosed foreign income and assets. In most cases,...

San Francisco CA - October 26, 2011 - The United States ("U.S.") and Korean Governments have entered into SCIP to combat tax evasion in the partnering countries.  The agreement between the U.S. and South Korea will allow the IRS to obtain records from South Korea's National Tax Service (NTS) to...

On August 26, 2011, the IRS extended the deadline for new applicants to the OVDI program and to those previously admitted to the program but seeking extension to: September 9, 2011. For those admitted to the program but need more time to gather required documents, including but not limit to,...

For those taxpayers who are still considering whether to apply for amnesty under the 2011 Offshore Voluntary Disclosure Initiative (OVDI) or who have not yet completed the program, you should be aware that the August 31st deadline is not only to file the initial application to the program but also...

The Disclosure Dilemma With the 2011 Offshore Voluntary Disclosure Initiative coming to a close on August 31, 2011, many U.S. citizens, green card holders, visa holders and other residents with undisclosed overseas accounts are wrestling with whether to disclose their foreign bank account(s) and other foreign financial activity. This includes...

Can the IRS Automatically Assess a Penalty against a U.S. Taxpayer who Innocently or Mistakenly Failed to Disclose a Foreign Bank Account? What happens in cases where a U.S. taxpayer innocently or mistakenly failed to disclose a foreign account and mistakenly failed to report foreign source income? Is such a...

The Overseas Citizenship of India program was instituted in 2006 to allow certain people who are of Indian origin to be granted particular citizenship rights even if they currently hold citizenship in another nation. The Constitution of India does not allow dual citizenship, but the Overseas Citizenship of India program...

Individuals and companies in the United States are required to account for income and pay appropriate taxes on foreign investments.  This is not a new tax requirement, just one that readily enforced by the Internal Revenue Service. The Department of Justice is seeking maximum enforcement. The Commissioner of the IRS...