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Common FBAR errors

The FBAR form is a reporting requirement for certain foreign financial accounts. The penalties for failing to file an FBAR are no joke. The IRS can apply a $10,000 penalty for each non-willful violation of the filing requirement.

Streamlined Offshore Disclosure Eligibility

When trying to determine if you are eligible for the IRS Streamlined Offshore Disclosure Program, the first thing to ask yourself is, "Do I have criminal exposure?” If the answer is yes, it's likely in your best interest to avoid the Streamlined program altogether; instead, you would probably ...

Should I file a Streamlined Submission or use the Full OVDP?

Too many people, realizing they have a problem with issing FBARs, Form 8938 and income overseas panic. They go to and become convinced that they need to enter into the full Offshore Voluntary Disclosure Program (OVDP) --- or else. The problem is that once you go full OVDP, you can't go back, even if the Streamlined program was the most appropriate choice. In this article we will add some perspective on who should use the full OVDP and those who should use the Streamlined program.

The benefits of using IRS streamlined disclosure program for missing or incorrect Form 5471s

IRS Report of Foreign Bank Account (FBAR) penalties are outrageous. But there are other, lesser known penalties that could devastate an international entrepreneur, or even a US retiree living abroad. These are Form 5471 penalties.

What to do with Offshore Voluntary Disclosure Program regrets

If you were a reasonable person, and weren’t an expert on IRS criminal and civil process, but rather, relied upon what the IRS claimed on their website, you would likely be convinced, that no matter what your criminal intent was, you must enter in Offshore Voluntary Disclosure Program (OVDP) or else. This article is about what to do if you realized you were scared into something you should not have done.

IRS targets Streamlined Submissions with Audits

For years the IRS has been saying that Streamlined Submissions for offshore accounts would be ripe fodder for audits. But, we never saw any evidence of them doing so. Until...

The Maze Streamlined Litigation case --- our take

Three retired taxpayers had undisclosed offshore accounts. All three of them made innocent mistakes. They were frightened into entering into the 2012 IRS Offshore Voluntary Disclosure Program (OVDP) where they would have to pay a 27.5% penalty on account value. The IRS then changed the rules to allow for a lower penalty. These elderly tapaxayers attempted to have this 5% penalty applied to them, but were frustrated.

OVDP for your foreign corporation or other entity?

The IRS Offshore Voluntary Disclosure Program (OVDP) is not just for individuals. Thanks to a harsh and extensive international tax form penalty regime, there can be a great incentive to enter into an offshore program to cure any of these unfiled or substantially incomplete forms:

"No" on Schedule B Part III line 7a?

You are required to file Schedule B with your IRS form 1040 each year if among other reasons, you had a financial interest in, or signature authority over a foreign financial account. On Schedule B Part III line 7a, the form specifically asks you to state whether or not you had a foreign account. The problem is...

What to do about a frozen Swiss and other bank accounts

Certain financial institutions --- not just in Switzerland --- are threatening and actually freezing bank accounts for lack of US tax and bank reporting compliance. In this article, we will explain why bank accounts are usually frozen and the action you may be able to take to regain access to your funds once again. 

Streamlined Foreign Offshore Eligibility

The liberalized 2014 Streamlined Foreign Offshore Process eligibility were on June 18, 2014 and remain in effect as of this writing.  There are many benefits to this disclosure program, mainly a 0% offshore penalty by default. In this article, we outline the steps to determine if you are eligible, and the procedure to complete a successful streamlined...

Streamlined Offshore Procedure due dates

Under the rules of the Streamlined Offshore Procedures, taxpayers must amend three years of U.S. tax returns, starting with the most recent year that has passed its due date, and then going backwards.

FATCA, OVDP, and Streamlined case studies

Offshore disclosures and FBAR penalties are a focus of the IRS. The law, procedures and actual outcomes are constantly evolving --- and sometimes the IRS operates inconsistently. To...

OVDP v. Streamlined: When 27.5% can actually be less than 5%

The standard Offshore Voluntary Disclosure Program (OVDP) "offshore penalty" on unreported foreign account is 27.5% of account values. Meanwhile, the Streamlined Domestic Offshore Procedures (SDOP) is 5% of the penalty base. So, it follows that the SDOP penalty should always be a better deal ...

Double-Secret OVDP and Streamlined Payment Plans

What are my options if I can't pay an offshore disclosure? You absolutely can negotiate with the IRS, and just because they say you owe something doesn't mean that's what you will end up paying.

Expats and IRS disclosure issues

Being a US person and living overseas isn't a crime (even though it may sometimes feel like it). Expatriates, more commonly known as expats, are US citizens residing overseas. That part at least is simple. How the US tax code treats these citizens is where everything devolves into chaos. It's ...

Maerki Baumann & Co. added Blacklisted Swiss Bank list

Since our last update on the "blacklisted" Swiss banks, a handful more have been added to the IRS Foreign Financial Institution List, including: Banque Internationale a Luxembourg (Suisse) SA (effective 11/12/15) Zuger Kantonalbank (effective 11/12/15) Standard Chartered Bank ...

Our streamlined submission review service

We have been getting a lot of request from  people who are interested in getting our legal opinion on a streamlined submission review that are about to make with the IRS. The fact is, many people want to do this themselves, or have their own tax professional do it. But the risk is that some ...

OVDP Feedback Part V & VI: Form 14708 and Form 14654

The IRS asked for feedback on its Offshore Voluntary Disclosure Program and Streamlined Procedures. Here is our response.   On October 16th, members of the IRSMedic Offshore Team presented detailed suggestion on how the IRS can best improve their offshore disclosure processes. In Part VI of ...

More Blacklisted Swiss Banks: What to do when the IRS takes over

On Thursday (October 29, 2015), the US Department of Justice announced new additions to the Swiss Bank Program that will soon be added to the "Blacklisted" Foreign Financial Institutions List: Luzerner Kantonalbank AG (Luzerner), Habib Bank AG Zurich (HBZ), Banque Heritage S.A.,Hyposwiss Private Bank Genève S.A. (Hyposwiss Geneva)

Offshore Tax Problems: It's good to be the king

Since the 2011 Offshore Voluntary Disclosure Initiative was first announced, and as it has evolved into the full - fledged 2012 Offshore Voluntary Disclosure Program (OVDP) and eventually into the current 2014 OVDP complete with the Streamlined Procedures, I have been fairly consistent in ...

Feedback: OVDP Parts I & II Form 14457 Offshore Voluntary Disclosure Letter

The IRS asked for feedback on many of its current and proposed OVDP and Streamlined Process forms. In the video immediately below, we describe our response. In Part II, which follows, we discuss change the IRS should make to OVDP Form 14457 the Offshore Voluntary Disclosure Letter.

OVDP and Streamlined Procedures Feedback and Suggestions

In the August 26, 2015 Federal Register, the IRS asked for feedback on current and proposed Offshore Voluntary Disclosure Program (OVDP) and Streamlined Process Forms. In particular, the IRS asked for comments and suggestions on the following: OVDP Form 14457 Offshore Voluntary ...

September 2015 OVDP Webinar

Thanks to all who joined us on our live OVDP Webinar on September 11th.  It was a great success -  be sure to check back in for additional live webinars as they come back in. Below is the webinar as well as the transcript.


Here at Parent & Parent LLP, we have been helping clients with offshore reporting issues for over 10 years. Here are some of the most commonly asked questions that we hear. I reported all my taxable income but haven’t filed my FBARs. Do I need to enter into the a program? This is actually a ...

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