What is a Closing Agreement and When Will One Be Entered Into by the IRS?

Last week's blog post, here, discussed the details of the Internal Revenue Service "Voluntary Disclosure Practice" (VDP). VDP is the one and only method for voluntary disclosures that apply to criminal tax activity, regardless if the activity involves offshore issues or strictly domestic ones. The final conclusion of a taxpayer’s entry into the Voluntary Disclosure … Continue reading What is a Closing Agreement and When Will One Be Entered Into by the IRS? →

IRS Voluntary Disclosure Practice and Closing Agreement: Understanding the Basics

The Internal Revenue Service (IRS) Voluntary Disclosure Practice (VDP) is alive and well. Its parameters are set out in Internal Revenue Manual (IRM) provisions dedicated strictly to the VDP. IRM 9.5.11.9.1 Voluntary Disclosure Practice, is available here. Under the VDP, the nature and extent of penalties to be assessed against a taxpayer will, to a … Continue reading IRS Voluntary Disclosure Practice and Closing Agreement: Understanding the Basics →

Want Protection from Criminal Prosecution for Tax Noncompliance? IRS Provides Only One Way

As many will remember, the Offshore Voluntary Disclosure Program (OVDP) closed on September 28 2018 with the promise that the Internal Revenue Service (IRS) would issue new guidance on voluntary disclosures made after that date. The guidance arrived on November 20 2018 in the form of a 5-page Memorandum (IRS Memorandum LB&I-09-1118-014) (“Memorandum”) by the … Continue reading Want Protection from Criminal Prosecution for Tax Noncompliance? IRS Provides Only One Way →

Did you Join OVDP? You’d Better Still be in Tax Compliance!

The Internal Revenue Service (IRS) has now expanded its compliance campaigns and included “post Offshore Voluntary Disclosure Program compliance” on the list. On July 19th, the IRS through its Large Business and International (LB&I) Division announced six new “compliance campaigns” for taxpayers. Significantly, one of these campaigns targets taxpayers who had entered an Offshore Voluntary Disclosure Program (OVDP) … Continue reading Did you Join OVDP? You’d Better Still be in Tax Compliance! →