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November 2014 Archives

Taxpayers Will Face a Difficult 2015 Filing Season

The Internal Revenue Service is unlikely to win an award as most popular federal agency. No one enjoys seeing a portion of their earnings taken away due to the tax laws. Many may characterize interactions with the agency as "miserable," However, one does not expect that characterization to come from the IRS Commissioner.

"Non-willfulness" under Streamlined Domestic or Foreign Offshore

Since the inception of OVDP, there has been a lot of talk within the tax community about the definition of "non-willful" FBAR violations. Verifying and supporting a Taxpayer's "non-willfulness" became even more important with the IRS published new guidance on the Streamlined Program. Under the new Streamlined Domestic Offshore Procedures ("SDOP"), those who qualify can elect to be considered under the new rules by certifying non-willfulness. Accepted applicants would be eligible for a 5% offshore penalty. For those residing outside the United States, the Streamlined Foreign Offshore Procedures ("SFOP") is available. If successful, those Taxpayers living abroad pay $0 penalty for their failure to file the FBAR.

Maryland Tax Attorneys
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Fax: 301-424-7047

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