OVDP PARTICIPANTS: CONTACT YOUR TAX ATTORNEY IMMEDIATELY – JUNE 30TH DEADLINE

The New Streamlined Filing Compliance for U.S. Persons Living Inside the U.S. and How for a Very Brief Period of Time the Participants of the OVDP may Significantly Benefit the Program Up until last week, the 2012 Streamlined Filing Compliance Procedures offered by the Internal Revenue Service ("IRS") were limited...

Foreign Bank Accounts and Other Foreign Financial Assets Reporting Regulations Take Effect July 1 2014

Part 1 While many tax reporting requirements have been in place for many years, the Foreign Account Tax Compliance Act (FATCA) set to take effect on July 1, 2014 establishes enhanced due-diligence and information reporting requirements, both for individuals and foreign banks. This will provide the IRS with an increased...

Another Way to Identify Income Underreporting – 1099K

Form 1099-K is a new information return sent to businesses by "payment settlement entities" (i.e., organizations responsible for reporting payments made by credit cards) reporting the amount of credit card and other electronic receipts that were processed for the business. The IRS also receives a copy of Form 1099-K and...

Offshore Voluntary Disclosure and Tax Compliance

Our team of experienced tax attorneys can help you become compliant with the Internal Revenue Service and minimize or eliminate your exposure to any offshore penalties and other problems. Offshore Voluntary Disclosure Representation One option individuals who have unreported foreign bank accounts and have underreported or failed to disclose foreign...

Pre-Immigration Tax Planning

The decision of a nonresident alien to move to the United States and become a U.S. citizen or resident alien will invoke significant tax considerations involving the interaction of the tax systems of the United States and the alien's current country of residence.  This includes both consequences under U.S. law...

Qualified Quiet Disclosure

Several options exist for individuals with prior undisclosed foreign assets and/or income to become compliant with the IRS.  Two of the more commonly used choices are the Qualified Quiet Disclosure and the Offshore Voluntary Disclosure Program ("OVDP"). Taxpayers entering into the Offshore Voluntary Disclosure Program must agree to several requirements. ...