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Caplin & Drysdale International Tax Alert

Caplin & Drysdale, Chartered - International Tax Alert Recent Developments Relating to FBARs and Offshore Voluntary Disclosure Program By Lucy S. Lee and Scott D. Michel Last week was a busy week for the IRS. The IRS has made several important announcements regarding the terms and deadlines...

Additional FBAR Relief for Certain Foreign Financial Account Signatories

by Keith J. Blum , Partner - Boies, Schiller & Flexner LLP On June 16, 2011, the IRS, in Notice 2011-54, further extended the deadline from June 30, 2011, to November 1, 2011, for the filing of the Report of Foreign Bank and Financial Accounts (FBAR) for persons with no financial interest in a...

IRS Announces Another Offshore Voluntary Disclosure Program

The IRS seems to have taken a nod from the legendary Yankee backstop, Yogi Berra, because "it's déjà vu all over again." On January 9, 2012, the IRS announced that it was "reopening" the Offshore Voluntary Disclosure Program (OVDP) for an indefinite period. This...

Filing Compliance Procedures Challenge U.S. Taxpayers Residing Overseas

Generally, [the 2012 Offshore Voluntary Disclosure Program] OVDP is designed for those delinquent U.S. taxpayers who have been holding financial assets overseas, have not been disclosing such assets to the U.S. government, have not been reporting the income produced from such assets, and...