Category Archives: OVDP

In an increasingly connected economy, it’s important that private citizens and business owners tread carefully with tax implications both at home and abroad.

If you have tax issues stemming from underpayment or non-disclosure of foreign assets, you may have heard of the “OVDP” — the IRS’ Offshore Voluntary Disclosure Program. It’s a program the IRS offers taxpayers who are exposed to potential criminal liability and/or substantial civil penalties, due to mishandling of tax payments due on their foreign […]

A major change in the way taxpayers could disclose foreign bank accounts happened in June of 2014 when the IRS implemented changes to its OVDP and streamlined reporting programs. Among the changes made to the OVDP is an increase in the miscellaneous offshore penalty from 27.5% to 50% where the individual had an account at […]

Also Referred to as the 2014 OVDP. The 2014 OVDP is a continuation of the 2012 OVDP but for a few changes.  This article attempts to highlight the changes and discuss why they are significant.  The changes are as follows: Increased 50% Penalty A 50% offshore penalty applies if either a foreign financial institution at […]

Another Swiss executive joins the growing list of Swiss bankers and executives who have been charged with allegedly aiding wealthy Americans in tax evasion. Raoul Weil, former head of UBS’s global wealth management business and a Swiss Citizen, was arrested in Bologna on October 19. In November 2008, when he was still working with UBS, […]

On June 7, 2013, Switzerland signed a Memorandum of Understanding (MOU) with the US on interpretations regarding US Foreign Account Tax Compliance Act (FATCA). The Swiss Federal Department of Finance stated: “Within the scope of the negotiations, both sides agreed to set out individual interpretations of a technical or administrative nature in a MOU.” Legislation […]

IRS to get names of U.S. taxpayers banking with Wegelin & Co. through a Connecticut based correspondent account with UBS. On January 28, U.S. District Judge William H. Pauley III signed an order in Manhattan federal court that authorized the IRS to serve a summons on UBS, the largest Swiss bank. The summons demanded that […]

Will my foreign real estate (property) be included in the calculation for the 27.5 OVDP FBAR penalty? One issue that comes up often is how foreign real estate effects how much our clients would owe under the 2012 IRS Offshore Voluntary Disclosure Program (known as the 2012 OVDP or IRS amnesty for offshore bank accounts […]