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Under the Streamlined Voluntary Disclosure Program, there is no penalty on the taxes that are due – although interest is due for each year of tax liability. While it sounds very “Cloak and Dagger,” it’s not – it is the same site whether you have accounts in Switzerland, Cayman Islands, Bahamas, Japan or India. While the IRS likes to keep this term a big secret, it generally means a person acted with either Intent, Knowledge or Reckless Disregard in not reporting Foreign Accounts, etc. It is based on a totality of the circumstances surrounding the non-disclosure.
My name is Steve Plotnik, I am experienced and dedicated to helping people like yousolve your IRS Offshore Voluntary Disclosure problems. Due to this, you will need personal service from someone like me who can offer knowledgeable, personal assistance. Plotnik and Associates is a CPA firm, do not act upon this information without seeking the service of a CPA, lawyer, or other financial professional who is well versed in your particular situation. In other words, a person must make a full submission during the process. Eligibility for IRS Voluntary Disclosure Program is different than the streamlined program.
But it is absolutely essential that you very carefully discuss this option with your advisor in order to fully understand your risks before you decide to move forward with it. In our previous blogs in this series, we discussed the two main ways U.S. expats can address their tax delinquency in the U.S. We discussed using theStreamlinedprocedure as well as filing via the traditional Offshore Voluntary Disclosure Program .
Fox Rothschild LLP is a national law firm known for excellent client service and agility in problem solving. Our lawyers provide a full range of services to public and private companies, from startups to multinational corporations, and prominent individuals, including celebrities, athletes, artists and entrepreneurs. Founded more than a century ago, Fox has grown significantly in recent years and is now ranked in the AmLaw 100, with 750 attorneys in 22 offices coast to coast.
Revisiting their pre-existing practices is necessary to ensure compliance with the evolving Fatca Filing – https://iwtas.com/what-is-a-withholding-agent-and-why-are-they-important/ landscape. Kunal has been really helpful in getting me compliant per the streamline procedures. Kunal was aware of all the nuances related to FATCA and FBAR procedures and gave appropriate recommendation and advice. The group includes former government officials from the IRS, Department of Justice and the Treasury who have strategic relationships within Congress and who have presented before the Senate Finance and House Ways and Means Committees.
If the amount is quite high and 5% is in fact a large figure, it makes sense to roll the dice in the hopes of reducing the penalty. Think of it as “hiding in plain sight.” The risk is that if you get spotted you are, well, in plain sight. You are at the mercy of the auditor, and auditors have recently been instructed to crack down on quiet disclosures. I’ve been putting clients through the IRS’ Offshore Voluntary Disclosure Program and while they have been making efforts to simplify it over the years, there are some very complex details to consider, options to weigh, and judgment calls to make. In fact, FATCA itself doesn’t actually require U.S. citizens to do anything.
Generally, if you were non-willful and you want to get into compliance, your immigration status should be safe. We have worked with many clients who have been surprised by the IRS, and these IRS “introductions” come in all shapes and sizes. Our office technology allows clients to meet virtually via GoToMeeting.
There are two types of streamlined OVDP disclosures depending on whether the violator was a resident or non-resident when the filings should have been made. The Statement of Understanding (completed by U.S. citizens seeking to relinquish U.S. citizenship) provides in part that renunciation may not provide exemption from U.S. income taxation. If the Department of Homeland Security determines that the individual renounced for the purpose of avoiding taxation by the United States, Section 212 of the Immigration and Nationality Act provides that the individual will not be admitted to the United States. An applicant for an original SSN who is under age 12 may apply by mail. The applicant can send the completed Social Security form SS-5 and required proofs to the servicing FBU.
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