IRS Reminder – Offshore Voluntary Compliance Program (OVDP) Ends September 28, 2018

The IRS recently released a reminder that taxpayers have until September 28, 2018 to apply for the OVDP. While the Streamlined Filing Offshore Procedure (SFOP), Streamline Domestic Offshore Procedures (SDOP) and Delinquent International Information Return (DIIR) programs remain open, the OVDP is the only program to reduce penalties and avoid potential criminal sanctions for persons…

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New Disclosure Requirements for US LLCs and other Business Entities owned by Non-US Persons

On 13 December 2016, the Department of Treasury and Internal Revenue Service (“IRS”) issued final regulations creating reporting and record keeping requirements for US disregarded entities owned by non-US person. A disregarded entity is any entity with a single owner and is disregarded from its owner for US tax purposes.  The IRS realized that US…

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IRS Proposes Changes to Reporting Requirements for Foreign Owned US Disregarded Entities

Internal Revenue Bulletin 2016-21, issued May 23, 2016, by the Internal Revenue Service (IRS) and Treasury Department included a notice of proposed rulemaking altering the reporting requirements for US disregarded entities owned by non-US persons or entities. A US disregarded entity is an entity with a single owner that is not treated as separate from…

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US Tax Compliance And Planning For US Executives, Entrepreneurs And Investors Living Outside The US

The article was first published in  Global Tax Weekly, issue 170. Below is the full text of the seventh article in the series on US taxes for US persons living outside the US. US Tax Compliance And Planning For US Executives, Entrepreneurs And Investors Living Outside The US by Stephen Flott, Omar Saleh, and Louisa…

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US Tax Compliance and Planning – The Offshore Voluntary Disclosure Program (OVDP)

By: Joseph Siegmann, and The Internal Revenue Service (IRS) created the Offshore Voluntary Disclosure Program (OVDP) and the Streamlined Domestic Offshore Procedure (SDOP) to encourage taxpayers to disclose foreign accounts and income that were subject to reporting but were not previously reported to the IRS. While both the OVDP and SDOP encourage taxpayers to disclose…

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