OVDP Ending – FAQs from the IRS

1.  Is the 2014 OVDP closing? Yes. The IRS will close the 2014 OVDP effective September 28, 2018. The FAQs for the 2014 OVDP provided that the program may close stating: “[T]he terms of this program could change at any time going forward. For example, the IRS may increase penalties or limit eligibility in the program for all or some taxpayers or defined classes of taxpayers – or decide to end the program entirely Read More

IRS to end offshore voluntary disclosure program; Taxpayers with undisclosed foreign assets urged to come forward now

WASHINGTON – The Internal Revenue Service today announced it will begin to ramp down the 2014 Offshore Voluntary Disclosure Program (OVDP) and close the program on Sept. 28, 2018. By alerting taxpayers now, the IRS intends that any U.S. taxpayers with undisclosed foreign financial assets have time to use the OVDP before the program closes. “Taxpayers have had several years to come into compliance with U.S. tax laws Read More

IRS instructs its auditors on IRC 6038A summons issuance and taxpayer noncompliance

From ThomsonReuters In an International Practice Unit (IPU), IRS has set out for its auditors the steps they should take when issuing a summons under Code Sec. 6038A and the steps to take if the domestic corporation to which it issues the summons does not substantially comply with the summons. Code Sec. 6038A requires reporting by domestic corporations that are at least 25% foreign owned. Background. Subject to Read More

Initial IRS Audit Campaigns Include Several International Tax Issues

From Lexology On January 31, 2017, the IRS Large Business and International Division (LB&I) announced its initial tax compliance campaigns. In 2016, LB&I began moving toward issue-based examinations, announcing it would focus its limited audit resources on enforcement “campaigns” with respect to issues having high compliance risk for large groups of taxpayers. As anticipated, the initial list has a heavy Read More

IRS Atty ‘Broke Bad,’ Sold Meth In The Mail, Say Prosecutors

From Law360 By Kat Greene Law360, Los Angeles (February 1, 2017, 7:21 PM EST) -- An attorney for the Internal Revenue Service had “better call Saul” after prosecutors on Wednesday arrested and charged the former Debevoise & Plimpton LLP associate and Georgetown Law ethics teacher with conspiring to ship distribution levels of methamphetamine to Long Island from his apartment in Washington, D.C. Jack Vitayanon, Read More

Tax Court Confirms $17M Informant Award For Whistleblowers

From Law 360 By Chuck Stanley Law360, Washington (January 31, 2017, 5:21 PM EST) -- The U.S. Tax Court on Friday awarded husband-and-wife whistleblowers $17.8 million for their role taking down a $74 million corporate tax fraud scheme, denying the IRS’ motion for reconsideration. The decision upholds the court’s previous ruling that awards to whistleblowers should be based on all of the money collected by the U.S. Read More

Additional Pleas to Offshore Account Tax Crimes

DOJ Tax announces, here, the plea to three U.S. offshore account holders.  The banks are the usual suspects -- UBS, Credit Suisse, Bank Leumi and others -- in Switzerland and Israel.  Each of the three related persons -- Dan Farhad Kalili, David Ramin Kalili and David Shahrokh Azarian -- pled to one count of failure to file FBARs, a five year felony.  Sentencing is later. The key excerpts are: Beginning in May Read More

Dormant Accounts: How a Theft Changed Swiss Banking

From FiNews It is twenty years now that a night guard stole documents destined for the shredder at the predecessor of UBS in Zurich. The theft indirectly caused one of the biggest ever crisis for Swiss banking. And is exemplary for the woes of a once proud industry. Christoph Meili was doing his shift at Union Bank of Switzerland in the night to January 9, 1997, when he spotted documents ready for destruction. Read More

Weisberg Kainen Mark, PL Featured by South Florida Legal Guide

Weisberg Kainen Mark, PL was recently featured by South Florida Legal Guide! Click here to read the feature. Read More

Westchester County Attorney Charged with Failing to File Tax Returns for Three Years

William O’Hagan, who is also a CPA, is accused of intentionally failing to pay NYS more than $86,000   The New York State Department of Taxation and Finance today announced the arrest and arraignment of a PricewaterhouseCoopers tax partner who allegedly failed to file his state personal income tax returns three years in a row. William J. O’Hagan, 56, of 940 King Street, Chappaqua, was charged with Read More