Monday, February 9, 2015

IRS Streamlined OVDP 2015 Updates

IRS Streamlined OVDP 2015 Updates

Recorded February 9, 2015 http://ift.tt/URFeVp The IRS announced its relaxed Streamlined Offshore Voluntary Disclosure Program (OVDP) in June of 2014. So what has happened since then? In this video we go over some the the updates as they have been put into practice. We discuss the many advantages of a streamlined OVDP and the critical differences for those who are "domestic" and those who are "foreign." We talk about some of the things that will stop you from being able to file an Streamlined OVDP, and some of the things, that might not matter. We discuss the types of non-willful individuals and entities that may or may not use the program. We discuss what happens if your Streamlined OVDP is audited. We discuss what you should do if someone told you were willful but you aren't sure you agree. We discuss why FATCA is feared but has been irrelevant to the IRS getting information. We explain how the IRS will go after CPAs and Attorneys with John Doe summonses first. Then compel those CPAs and Attorneys to "spill the beans" on their clients. And we finish by going over the particular issues for US account holders in Latin America, Western Europe, the Pacific Rim and Australia. More info: http://ift.tt/1DUK3gR http://www.irsmedic.com OVDP Hotline 888 477-4258 info@irsmedic.com Serving US taxpayers around the globe Parent, Parent & Wynn LLP 144 S. Main Street Wallingford, CT 06492 (203) 269-6699 http://ift.tt/1DUK3gN Anthony Parent

Thursday, December 18, 2014

FBAR Penalty Guide Updated 10-9-14

FBAR Penalty Guide Updated 10-9-14

http://bit.ly/1zagZTB In this updated webinar, recorded October 9, 2014, we discuss the entire history of the law that spawn this dreadful form -- the Bank Secrecy Act of 1970. The FBAR requirement was intended to catch the worst types of criminals, but now retired grandmothers, holocaust survivors, international sport stars -- people who had no intent to defraud the IRS of a penny, but found themselves on the wrong side of a bad law. The BSA Act is a failure and should go away. But is only if we lived in a sane world, with sane laws. http://ift.tt/10ExfNv In this video we discuss how to avoid significant FBAR penalties whether you are inside or outside an IRS OVDP. One of the worst things you could do is file a "soft" or "quiet" disclosures. We have heard cases of IRS District counsel loaded for bear and assessing 50% FBAR penalties simply in cases were taxpayers were given bad advice. Now, just because the IRS assesses an FBAR penalty, unlike taxes they have to sue you in federal district court to covert their assessment in to a judgment that means something They have to convince a jury you should be held willful. So if you have a appetite for litigation you may be frustrate IRS counsel from doing anything with their assessment; this is certainly a legitimate strategy when there are hundreds of thousands of dollars or millions of the line. http://ift.tt/1vbeI8E http://ift.tt/13idvR2 Anthony Parent

2014 OVDP Webinar UPDATED 7/17/2014

2014 OVDP Webinar UPDATED 7/17/2014

http://ift.tt/URFeVp The IRS announced significant changes, some helpful, some not, to the IRS Offshore Voluntary Disclosure Program (OVDP). The worst news is that for some holders of foreign accounts, a 50% offshore penalty will be automatically applied for the standard OVDP, for others it remains 27.5%. However, the IRS has indicated that this standard OVDP is really for the types of people the old tradition, pre-2009 Voluntary Disclosure program was intended for --- those with actual criminal exposure. For some people though who want protection from criminal charges, they can still use the standard OVDP and opt-out of the traditional penalty structure. However the legal fee for doing so, becomes very high as some of the simplified accounting processes like mark-to-market PFIC computations are NOT available during an opt-out. For most people, for those who made an innocent or negligent mistake, the steamlined programs offer a much better was to come clean than prior to the 2014 rules. The IRS somewhat clarified rules on those with unfiled FBARs but no other tax compliance. The look-back period is now 3 years, not 8. For those who meet the test for living overseas the offshore penalty is 0%. For those who live in the US, the offshore penalty is 5% but is based on highest year end balance, not highest balance during the year. Also certain assets come off the penalty base --- a significant change is foreign rental property. In 2013 and 2014 many US Swiss account holders were presented with an uncomfortable decision. Prove to their Swiss bank that they were in an OVDP or the Swiss bank would disclose their names to the IRS. As other countries implement the one our requirements of FATCA, letters will be going to to US taxpayers, even those who closed their account as long ago as 2009. http://ift.tt/1AMJZOl Anthony Parent

Tuesday, December 9, 2014

2014 OVDP Webinar

2014 OVDP Webinar

2014 OVDP Webinar http://ift.tt/1IvWqUE Anthony Parent

Wednesday, November 5, 2014

GTi is little but not bad

GTi is little but not bad

Sport mode! http://ift.tt/1x5nUN3 Anthony Parent

Thursday, October 23, 2014

Delinquent FBAR filing procedures and Streamlined OVDP FAQs

Delinquent FBAR filing procedures and Streamlined OVDP FAQs

http://ift.tt/1vUC95w For US expatriates who have reported all foreign-sourced income, or did not have any foreign income to report, the IRS has made the delinquent FBAR filing procedures *relatively* straight-forward and *relatively* easy to understand. But here's where things get ugly. This is only true for taxpayers who do not have any unreported income in the last 3 years. Things get complicated in situations where there in no unreported income in the last three years, but unreported income in any one of the three years prior. In this article we will demonstrate the apparent contradictions, and offer strategies for the not-too uncommon issue of having unreported foreign income, not in the last 3 years, but rather, 4-6 years ago. http://ift.tt/1xenMXD The IRS published Domestic Streamlined OVDP FAQs on October 8, 2014 --- purportedly to clear the air. The IRS is attempting to be intelligent and foresee the questions people will ask. The problem is we only see more confusion. Read more to judge for yourself. Commentary is interspersed with italics, to denote possible future changes, or items of inconsistency. 2014 OVDP Webinar http://ift.tt/URFeVp http://ift.tt/1D3x5f1 Anthony Parent

Monday, September 15, 2014

FBAR filing instructions -- don't follow the IRM

FBAR filing instructions -- don't follow the IRM

According to the Internal Revenue Service Internal Revenue Manual, Sec 4.26.16.3.7 (07-01-2008) link here: http://ift.tt/1Dcdpsp, "[t]he FBAR is filed by mailing it to the U.S. Department of the Treasury, Post Office Box 32621, Detroit, MI 48232-0621." But this is not true. We have an IRS webpage (linnk here: http://ift.tt/1eVVRov) that says the FBAR "is only available online through the BSA E-Filing System website." (link here: http://ift.tt/1bDpIB5) So if the IRS can't get its own FBAR rules straight, what kind of standard of conduct should they impose on you? http://ift.tt/1wxqB9t Anthony Parent