News & Analysis as of

Penalties Internal Revenue Service Voluntary Disclosure

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.

The Risks of an IRS Quiet Disclosure

Allen Barron, Inc. on

What are the risks of an IRS quiet disclosure? Is there a formal IRS process known as a "quiet disclosure," and does the IRS honor this strategy for amended tax returns?...more

Snell & Wilmer

Department of Justice Announces Groundbreaking Whistleblower Program in its Ongoing Effort to Incentivize Voluntary Self...

Snell & Wilmer on

Department of Justice (DOJ) Deputy Attorney General Lisa Monaco announced that the DOJ is adopting a whistleblower incentive program today at the American Bar Association’s 39th National Institute on White Collar Crime. In...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

Jackson Walker

IRS Announces Voluntary Disclosure Program for Employee Retention Tax Credits

Jackson Walker on

On December 21, 2023, the Internal Revenue Service (IRS) issued Announcement 2024-3, setting forth the parameters of a voluntary disclosure program (the “Program”) for taxpayers to resolve Employee Retention Tax Credit (ERTC)...more

BakerHostetler

Supreme Court Rules in Favor of Taxpayer in FBAR Case Penalty for Non-Willful Violations Apply on a Per-Report Basis

BakerHostetler on

On Feb. 28, the U.S. Supreme Court ruled that non-willful penalties related to FBARs apply to each report filed, not on a per-account basis. The 5-4 decision resolved a split between the Fifth and Ninth circuits that focused...more

Holland & Knight LLP

Same Statute, Same Form, Different Penalties: Welcome to FBAR Litigation

Holland & Knight LLP on

The "Report of Foreign Bank and Financial Accounts" (FBAR) penalty has been the subject of much litigation. This Holland & Knight alert focuses on the non-willfulness element of 31 U.S.C. § 5321(a)(5)(B). Both the U.S. Court...more

Thomas Fox - Compliance Evangelist

This Week in FCPA-Episode 56

This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: 1. The Kokesh case at the US Supreme Court is significant for SEC enforcement of the FCPA around profit...more

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