Nice analysis of the transition. Ends with:
“What remains unchanged is the need to consider each non-reporting case individually, based on its peculiar facts and circumstances, and, chart the least risky course to a safe harbor. This is why experienced professionals with sound judgment must advise clients on these complex and delicate issues.”
Yesterday, August 18, 2014, IRS announced and posted to the Offshore Voluntary Disclosure page on its website (www.irs.gov) significant changes to the 2012 OVDP reflected in revised Frequently Asked Questions; and, new Streamlined Filing Compliance Procedures for non-willful, out-of-compliance taxpayers, whether living abroad or here in the states. These new FAQs and procedures apply generally to OVDP submissions made after June 30, 2014.
The major changes to the 2012 OVDP are:
- The 27.5% Offshore Penalty generally remains in place for participants but a 50% Offshore Penalty may apply, beginning with names submissions made on or after August 14, 2014, to those participants with foreign accounts at foreign financial institutions (FFI) about which public disclosure has been made of:
- An IRS or DOJ investigation.
- That the FFI is cooperating with IRS and DOJ, or,
- A John Doe summons being served on the FFI.
- FAQ 7.2 defines public…
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