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Audits Penalties Offshore Funds

Allen Barron, Inc.

IRS Revisions to the Voluntary Disclosure Program for 2024

Allen Barron, Inc. on

What are the IRS revisions to the Voluntary Disclosure Program for 2024? The foundation of the current IRS Voluntary Disclosure Program (VDP) goes as far back as 2009 when the agency worked to provide U.S. taxpayers with a...more

Allen Barron, Inc.

Questions Regarding Offshore Accounts and FBAR Filing Requirements

Allen Barron, Inc. on

Many US taxpayers still have questions regarding offshore accounts and FBAR filing requirements and compliance. Is there a genuine risk their activities (or lack of compliance) will come to light? The definition of a US...more

Allen Barron, Inc.

What is the IRS Offshore Voluntary Disclosure Program?

Allen Barron, Inc. on

What is the IRS Offshore Voluntary Disclosure Program and who is it designed to help? What are the guidelines for voluntary disclosure to the IRS and who is eligible to apply? The IRS Offshore Voluntary Disclosure...more

Allen Barron, Inc.

Are There Strategies to Avoid an IRS Audit?

Allen Barron, Inc. on

Are there strategies to avoid an IRS audit? What are some of the known risks for triggering an IRS audit? What should you do if you have are concerned about the information provided a previous tax return? Is there a way to...more

Holland & Knight LLP

Willful or Non-Willful? That Is the Question: IRS Rejects Non-Willful Certification

Holland & Knight LLP on

In Flint v. United States, 2022 WL 3593826 (Fed. Cl. 2022), the court held that the executors of an estate could not recover a six-figure "Title 26 miscellaneous offshore penalty" (MOP) the decedent paid to the Internal...more

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