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IRS Issues Final Regulations Governing Foreign-Owned Single Member LLCs

In International Tax, Offshore Tax by Jason FreemanLeave a Comment

In December, the IRS issued final regulations that treat a domestic disregarded entity that is wholly owned by a foreign person as a domestic corporation separate from its owner for purposes of the reporting, record maintenance, and associated compliance requirements that apply to 25-percent foreign-owned domestic corporations under section 6038A of the Internal Revenue Code.  A link to the final …

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IRS Offshore Compliance: New Stats Indicate a Slow in OVDP Submissions

In International Tax, Offshore Tax, OVDP by Jason FreemanLeave a Comment

The IRS has announced updated statistics for its two primary offshore compliance programs: The Offshore Voluntary Disclosure Program and the Streamlined Filing Compliance Procedures.  And the new data tells an interesting story.  All told, some 55,800 taxpayers have now come into the OVDP, paying in more than $9.9 billion in taxes, interest and penalties since the 2009 version of the …

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Government Report Finds that Improvements are Needed in the Offshore Voluntary Disclosure Program

In International Tax, Offshore Tax, OVDP by Jason FreemanLeave a Comment

TIGTA initiated an audit to assess how well the IRS is managing the OVDP.  TIGTA specifically looked into the IRS’s efforts to improve taxpayer compliance and to hold accountable taxpayers who fail to report their offshore financial activities on their tax returns or on a Report of Foreign Bank and Financial Accounts (FBAR).  In a report released this summer, TIGTA …