News & Analysis as of

Disclosure Requirements › Tax Evasion › Internal Revenue Service

Eversheds Sutherland (US) LLP

IRS Removes Willfulness Checkbox from Form 14457, Easing Path for Voluntary Disclosures

Eversheds Sutherland (US) LLP on

In a significant policy shift, the IRS has revised Form 14457, Voluntary Disclosure Practice Preclearance Request and Application, the cornerstone of its Voluntary Disclosure Practice (VDP), by removing the controversial...more

Allen Barron, Inc.

US Taxpayers and Expatriates May Need to File Offshore Disclosures and FBARs

Allen Barron, Inc. on

How many U.S. taxpayers and expatriates may need to file offshore disclosures and FBARs with the IRS? Should those who have not yet filed a disclosure application utilize the VDP (Voluntary Disclosure Program) or a...more

Allen Barron, Inc.

Offshore Real Estate Ownership and Tax Reporting Requirements

Allen Barron, Inc. on

What do you need to know about offshore real estate ownership and any associated tax reporting requirements? Are you a U.S. taxpayer or U.S. resident who owns real estate outside of the United States? It may surprise you to...more

Proskauer - Tax Talks

Proposed Regulations Issued on Reporting Obligations for Basket Contract Transactions

Proskauer - Tax Talks on

On July 12, 2024, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued proposed regulations that would classify “basket contract transactions”, which are derivatives (i) with a term...more

Allen Barron, Inc.

What is the IRS Offshore Voluntary Disclosure Program?

Allen Barron, Inc. on

What is the IRS Offshore Voluntary Disclosure Program and who is it designed to help? What are the guidelines for voluntary disclosure to the IRS and who is eligible to apply? The IRS Offshore Voluntary Disclosure...more

Burr & Forman

IRS Announces End to Foreign Bank Account Disclosure Program: What Can You Do Now If You Still Have Unreported Foreign Bank...

Burr & Forman on

The IRS recently announced it will be shutting down its successful Offshore Voluntary Disclosure Program (OVDP) for unreported foreign bank accounts and income. The program will end September 28, 2018. Under the OVDP, first...more

Blank Rome LLP

Justice Department Announces That Three More Swiss Banks Reach Agreements Over Tax Evasion Claims

Blank Rome LLP on

On July 30, 2015, the Justice Department’s Tax Division announced that three more Swiss banks — PKB Privatbank AG, Falcon Private Bank AG and Credito Privato Commerciale in liquidazione SA (CPC) – have cut deals with the U.S....more

K&L Gates LLP

The Cloak of Invisibility for Foreign Accounts Is Rapidly Unraveling: IRS and Foreign Banks Are Clamping Down on U.S. Tax Evasion

K&L Gates LLP on

A global push for enhanced financial transparency means that United States owners of foreign accounts and assets will not be able to remain invisible forever. New rules and enhanced enforcement of existing rules will soon...more

CMCP - California Minority Counsel Program

The Offshore Voluntary Disclosure Program: A Brief History And Overview Of The Complexities Involved In Disclosing Foreign Assets

CMCP - California Minority Counsel Program on

The IRS and the Justice Department have increased their efforts regarding criminal investigation of international tax evasion. ...more

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