The Internal Revenue Service today announced the nationwiderollout of a streamlined program designed to enable small businesses under audit to more quickly settle their differences with the IRS. The Fast Track Settlement (FTS) program is designed to help small businesses and self-employed individuals who are under examination by the Small Business/Self Employed (SB/SE) Division of…
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IRS Using Every Resource to Find Taxpayers Who Made “Quite Disclosures” of Their Offshore Accounts
We have previously written on the topic of the “Quiet Disclosure” alternative for complying with U.S. offshore reporting requirements: IRS Collected $5.5 Billion From OVDI, But According to GAO, May Be Missing Billions More? IRS Cracks Down on "Quiet Disclosures" Quite Disclosure" Caught - DOJ Files To Collect 50% FBAR Penalty! Under this alternative,…
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Criminal Exposure for Late Filing Even If Qualify under FAQs!
In a recent appellate case, US v. Simon, 7th Circuit Court of Appeals, August 15, 2013, the taxpayer filed required FBAR’s late, using the filing procedure allowed for late filings under the 2009 OVDI FAQ. Nonetheless, the court found that the FAQ relief from civil penalties was not a bar to the government asserting criminal…
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Criminal Score Card Not Good For Offshore Account Holders!
In our previous post UBS Criminal Casualties, so Far and More Guilty Pleas Over Offshore Accounts in the Works! regarding the U.S. and Swiss Reach a Deal on American Tax Evaders, the IRS hunt for offshore income and accounts continues unabated. Now in the wake of H. Ty Warner, the billionaire creator of Beanie Babies plush toys, pleaded guilty last…
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