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On Nov. 29, 2018, the IRS released a memorandum with new procedures for all voluntary disclosures following the end of the Offshore Voluntary Disclosure Program (OVDP) on Sept. 28, 2018. The new voluntary disclosure procedures apply to both domestic and offshore voluntary disclosures. What’s Changed? Background OVDP was initiated in 2009 and designed to bring taxpayers with undisclosed foreign income, accounts, and assets into compliance for U.S. income tax purposes. Taxpayers who were eligible to…
The IRS announced that it will end the Offshore Voluntary Disclosure Program (OVDP), effective September 28, 2018.  The IRS is pressing taxpayers with undisclosed foreign accounts, entities and income to come forward before the September 28, 2018 deadline and become compliant.  Therefore, US taxpayers who have unreported foreign assets and income have a limited amount of time to participate in the OVDP before the program ends.  If they do not, they may face dire penalties,…
The IRS has designated certain syndicated conservation easement transactions as “listed transactions.” This will require taxpayers who have invested in such transactions to file a notice with the IRS. It will also result in reporting and list maintenance obligations for professionals (law firms, accountants, appraisers, etc.) who provided material advice on such transactions. If the required notice is not provided, severe penalties will be imposed. Conservation easements, a tax planning technique that has gained popularity with…
Come the end of September 2016, the Israeli Tax Authority will start forwarding data collected on U.S. citizens and green card holders with financial accounts in Israel to the U.S. Internal Revenue Service (IRS). This transferring of information is part of FATCA (the U.S. Foreign Account Tax Compliance Act of 2010), based on an agreement between Israel and the United States. While FATCA applies on a worldwide basis, the U.S. has entered into intergovernmental agreements (IGAs)…