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News – 30.10.24
Autumn Budget 2024: Were promises fulfilled or broken?
The Budget focused on Labour's bold plans to address the UK's finances and invest in infrastructure across health, education, housing, and transport. … Read more
Insight – 01.11.24
What to expect in the upcoming US election 2024 – Harris vs Trump tax policies
Here's what to expect in the upcoming US election 2024 – Harris vs Trump tax policies … Read more
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Effective September 2018, the IRS have officially closed the Offshore Voluntary Disclosure Program (OVDP), which was a voluntary disclosure program designed for taxpayers with exposure to potential criminal liability and/or substantial civil penalties due to a willful failure, to report foreign financial assets and pay all tax due in respect of those assets. However, the IRS are still committed to keeping the Streamlined Filing disclosure facility open for the time being.
The Streamlined Filing disclosure facility allows US taxpayers to file the last three late US tax returns and last six late FBARS with reduced penalties assuming the non-filing can be shown to be non-wilful.
With the withdrawal of the OVDP, it is our view that the IRS may look to close down or amend the terms of the Streamlined Filing Program in the near future. We therefore strongly advise you to contact us as soon as possible for advice on the IRS guidance on non-wilfulness.
There are alternative IRS procedures available to get information returns up to date in a penalty-free manner, subject to reasonable cause, for US taxpayers who have reported all of their foreign income on their US returns but have not filed their information returns, such as:
If you have already received a notice from the IRS demanding that you make a payment of taxes or penalties, or threatening a lien on your property, you may need to take some urgent action. Our team of experts is very experienced in handling correspondence with the IRS on behalf of our clients. Sometimes it takes persistence to bring an enquiry to a close but we will be able to achieve the best possible outcome for you.
In some cases, it may be advisable to draw on the expertise of a US qualified lawyer in order to determine the best approach and make sure your disclosure is as robust as possible. If so, we can help to find the right legal adviser for you.
For professional advice tailored to your unique circumstances, please fill out the form below and one of our experts will be in touch to discuss your requirements and how we can help. Please note that our advisory services are charged at our hourly rates and a formal engagement will need to be in place before any advice is provided.
