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Last Call: The IRS Will Soon Close the Offshore Voluntary Disclosure Program, Leaving a Limited Window to Obtain Criminal Amnesty

In OVDP by Jason B. FreemanLeave a Comment

The IRS recently announced that it will officially close the Offshore Voluntary Disclosure Program (“OVDP”) in September of 2018.  Its announcement serves as a “last call” for taxpayers who have willfully failed to report foreign assets or income—a last opportunity to come forward under the terms of the OVDP, which provides for criminal amnestyand other protections.  After September 2018, the …

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The Paradise Papers Continue to Shed Light on the Use of Offshore Tax Havens

In FATCA, FBAR, Offshore Tax, OVDP by Jason Freeman and Spencer BanksLeave a Comment

The Paradise Papers represent the latest large-scale leak of financial documents believed to link thousands of companies and individuals to hidden offshore accounts and secret tax havens.  The leak was massive, totaling some 1,400GB of data—that translates to an estimated 13.4 million documents covering a period from 1950 to 2016.[i]Nearly half of the leaked documents come from corporate registries in …

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Last Call: The Offshore Voluntary Disclosure Program to End

In OVDP by Jason B. FreemanLeave a Comment

With the IRS recently announcing that it intends to officially close the Offshore Voluntary Disclosure Program (“OVDP”) by September 28, 2018, it has formally issued a “last call” for taxpayers with willful foreign reporting deficiencies.  According to the IRS, the announcement of the coming end to the OVDP “reflects advances in third-party reporting and increased awareness of U.S. taxpayers of …

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The Brazilian Tax Amnesty Program: The Regime Especial de Regularização Cambial e Tributária

In OVDP by Jason B. FreemanLeave a Comment

Earlier this year, the Brazilian government put into place the Special Currency and Tax Regularization Regime (Regime Especial de Regularização Cambial e Tributária or “RERCT”), a fiscal amnesty program established by Law No. 13,254/2016 that allows holders of previously undeclared offshore assets to report those assets to Brazilian tax authorities.  The program is currently set to close on October 31, …