Publications
Offshore Voluntary Compliance and Streamlined Disclosure Programs
‘The Hazards of Common Reporting Standard Advice: Model Mandatory Disclosure Rules for CRS Avoidance Arrangements and Opaque Offshore Structures” 49 Bloomberg Tax Management International Journal No. 3 (March 13, 2020)
The Common Reporting Standard (CRS) is a regime for the exchange of financial account information among tax authorities of over 100 participating countries. Read more…
“IRS Brings the Hammer Down on those Who Waited” 48 Bloomberg BNA Tax Management International Journal 34 (January 4, 2019)
By Memorandum dated November 20, 2018 from Kirsten B. Wielobob, Deputy Commissioner for Services and Enforcement (the “Memorandum”), the Internal Revenue Service updated rules which will govern foreign and domestic voluntary disclosures following closing of the Offshore Voluntary Disclosure Program on September 28, 2018.
“IRS Announces Closure of 2014 Offshore Voluntary Disclosure Program: What Comes Next?” 47 Bloomberg BNA Tax Management International Journal 343 (May 11, 2018)
The 2014 OVDP is actually the fourth iteration of voluntary disclosure programs intended to encourage offshore compliance (collectively, the “OVDP Programs”).
“The Common Reporting Standard Comes to Canada” 127 Journal of Taxation 165 (October 2017)
While Canada is only one of 101 countries that have adopted the Common Reporting Standard (CRS), its legislation and guidance provide an example of CRS in practice.
“How Will They Catch Me? Let Me Count the Ways: Part One” 46 Bloomberg BNA Tax Management International Journal 275 (May 12, 2017)
How will they catch me? This question frequently comes up when counseling U.S. citizens living abroad who have neglected to become or remain U.S. tax compliant.
“How Will They Catch Me? Let Me Count the Ways: Part Two” 46 Bloomberg BNA Tax Management International Journal 329 (June 9, 2017)
The first part1 of this two-part article summarized the information sources from which the Internal Revenue Service may identify non-compliant U.S. citizens living abroad and their foreign accounts and assets. This part reviews the collection alternatives available to the United States government to recover delinquent taxes, interest, and penalties from its nonresident citizens.
“Considerations on Relying on a CLN as an Alternative to the OVDP and SFOP” 45 Bloomberg BNA Tax Management International Journal 148 (March 11, 2016)
Not all U.S. persons residing outside the United States find the OVDP or SFOP desirable options to address past non-compliance.
“FATCA, the U.S.-Canada IGA, and Trusts” 43 Bloomberg BNA Tax Management International Journal 255 (May 9, 2014)
FATCA is codified as §1471–§1474 of the Code. Its purpose is to enable the IRS to identify the beneficial owner of any foreign account if the account holder5 is a U.S. person and to create a mechanism whereby information regarding that person and the foreign account will be provided to the IRS in order to confirm the U.S. person’s compliance.