Showing posts with label OVDI. Show all posts
Showing posts with label OVDI. Show all posts

OVDI FBAR Use It or Lose It - HG.org

by Lance Wallach
The IRS has announced a reopening of its 2011 offshore voluntary disclosure initiative (“OVDI”). This program will have essentially the same terms as the 2011 OVDI, but with a penalty rate of 27.5 percent (rather than 25 percent) of the highest account balance during the period covered by the initiative.

The program requires filing eight years of amended tax returns and unfiled FBARs and the payment of tax, interest and a possible accuracy-related penalty on unreported income as well as the above-mentioned lump-sum penalty. In certain cases, a reduced penalty for failure to file FBARs is available. Unlike the prior initiatives, the reopened OVDI has no deadline; however, the government can always choose to impose a deadline or terminate the program at its discretion.

As in the past, yesterday’s move follows a carrot-and-stick approach in which the IRS announces an opportunity for delinquent filers to come clean, but only after the government first announces major enforcement actions. Although the relatively small increase in the penalty amount provides good news for taxpayers who are thinking of coming forward, the initiative nevertheless continues the unfortunate pattern of treating all disclosing taxpayers similarly, without regard to willfulness in failing to meet their compliance burdens. This one-size-fits-all approach seems particularly harsh in situations involving minimal tax liability or otherwise sympathetic facts.

The information provided herein is not intended as legal, accounting, financial or any type of advice for any specific individual or other entity. You should contact an appropriate professional for any such advice.

Lance Wallach - Articles - FBAR OVDI

Lance Wallach - Articles - FBAR OVDI

As an expert witness Lance Wallach side has never lost a case: Sometimes the IRS might disagree with planning you...

As an expert witness Lance Wallach side has never lost a case: Sometimes the IRS might disagree with planning you...: Sometimes the IRS might disagree with planning you did with other advisors and you need to find help to ensure that your rights are protec...




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  • FBAR/OVDI LANCE WALLACH: Foreign Bank Account ...

    multinationaltaxesfbarovdi.blogspot.com/.../foreign-bank-account-report...‎

    Jun 20, 2013 - ... filed an FBAR but should have --> you should immediately consult with a tax attorney familiar with international tax law or with a CPA that was  ...
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  • FBAR/OVDI LANCE WALLACH: FBAR & International Tax ...

    multinationaltaxesfbarovdi.blogspot.com/.../fbar-international-tax-alert-r...‎

    Dec 5, 2013 - Our office is headed by a former international tax IRS agent with 37 years experience as a CPA and Associate Professor of accounting. Call our  ...
  • Help with Common IRS Problems: Climbing Mt. Neverest - NATP - Lance Wallach

    Help with Common IRS Problems: Climbing Mt. Neverest - NATP - Lance Wallach: Climbing Mt. Neverest - NATP - Lance Wallach 419  412i plans IRS  audits lawsuits  | LinkedIn www.linkedin.com/.../ 419 -412i- plan s-IRS- ...





    Thursday, February 13, 2014


    FBAR/OVDI LANCE WALLACH: FBAR Offshore Bank Accounts and Foreign Income Att...

    FBAR/OVDI LANCE WALLACH: FBAR Offshore Bank Accounts and Foreign Income Att...: FBAR Offshore Bank Accounts and Foreign Income Attacked by IRSn August 31st 2012, the IRS announced a new streamlined filing programto allow qualifying U.S. citizens living abroad to catch up on outstanding U.S. tax returns and related information returns without penalties being imposed. Under this new program, which came into effect on September 1, 2012, individuals who qualify must:

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  • FBAR/OVDI LANCE WALLACH

    multinationaltaxesfbarovdi.blogspot.com/‎

    Mar 4, 2014 - June 30 2014 is the annual deadline for U.S. taxpayers, (including resident aliens) to timely reports of foreign financial accounts for year ending ...
  • FBAR Offshore Bank Accounts and Foreign Income Attacked by IRS. Lance Wallach, expert witness.

    FBAR/OVDI LANCE WALLACH: FBAR Offshore Bank Accounts and Foreign Income Att...: FBAR Offshore Bank Accounts and Foreign Income Attacked by IRSYou may want to think about participation in the IRS’ offshore tax amnesty program (called the Offshore Voluntary Disclosure Initiative). Do you want to play audit roulette with the IRS? Some clients think they are too small to be prosecuted. They are wrong.To the average businessperson, only the guys with tens of millions secretly stashed in Swiss bank accounts get prosecuted. Don't tell that to Michael Schiavo. He was just prosecuted for hiding money in a Swiss account back in 2003. How much money does the IRS say he hid? A whopping $90,000. That’s it.But wait, there is more to the story. Schiavo attempted to do a quiet disclosure during the 2009 amnesty but instead of filling out the amnesty paperwork, he simply trusted that by coming forward voluntarily he could avoid criminal prosecution. He was wrong on all counts. Nothing is too small for the IRS, and nothing is too old.“So, to save a whopping $40,624 in taxes, this guy risked a felony conviction and prison time, not to mention steep penalties that could very easily eat up the entire $90,000, and also his criminal and civil defense costs.

    The smart taxpayers are the ones coming forward and not having to look over their shoulders for the next 10 years.
    Time is running out. The tax amnesty runs through August but it takes at least days to jump through all the hoops. We will also fight hard to reduce the penalties down even more. Remember, the IRS can go as low as 5%.

    As an expert witness Lance Wallach's side has never lost a case. People need to be careful of 419 Welfare Benefit Plans, 412i plans, Section 79 plans and Captive Insurance Plans. Most of these plans are sold by insurance agents. If you are in an abusive, listed or similar transaction plan you need to file under IRS 6707a. The participant files form 8886, and the salesmen or accountant who signs the tax returns files form 8918 if they got paid over $10,000. They are called Material Advisors and face a minimum $100,000 fine. Some plans are offshore which could involve FBAR or OVDI filings. If you have money overseas you probably need to file for IRS tax amnesty. If you want to reduce the tax we suggest that you first file and then opt out. For more information Google Lance Wallach.

    The information provided herein is not intended as legal, accounting, financial or any type of advice for any specific individual or other entity. You should contact an appropriate professional for any such advice.