Tax & Sports Update

Last Call for the OVDP Program!

Posted by Joseph B. Darby III on Apr 19, 2018 12:50:58 PM

The IRS has announced that the Overseas Voluntary Disclosure Program (OVDP), which has been around since March 2009, is about to be shut down permanently, effective September 28, 2018.

The OVDP Program has seen over 56,000 taxpayers come forward voluntarily, paying over $11 billion in back taxes interest and penalties. The Program has always been a great deal for people who actually hid assets offshore, failed to report taxable income, and then want to come clean and get back into compliance, especially because the IRS is hot on everybody’s trail thanks to the FATCA regime and other enhanced offshore investigative techniques.

The IRS wants to terminate the Program because participation has declined steadily, from a peak of 18,000 disclosures in 2011, to only about 600 disclosures in 2017. However, the IRS is expected to maintain its aggressive posture on offshore tax avoidance, and so now is the last clear chance for people to take advantage of the OVDP Program and avoid severe sanctions (including criminal prosecution) for dubious past conduct.

Don’t miss this last call to help taxpayers come into compliance under this de facto “amnesty” program that ends on September 28, 2018. Call us at (617) 338-2985 if you or a client would like our assistance in “coming in from the cold” under the Program.

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Topics: Taxes, OVDP, IRS, offshore

The Gift That Keeps on Giving - To the IRS

Posted by Joseph B. Darby III on Mar 17, 2017 7:48:35 AM

GettyImages-508893778.jpgA rather stunning near–catastrophe almost occurred in the art world recently, and only dumb luck – namely, a casual off-hand remark with a savvy tax adviser  saved the art owner from a huge, self-inflicted tax bill from the Internal Revenue Service. A non-U.S. taxpayer (meaning a non-resident alien in tax parlance) had an extremely valuable painting being displayed in a U.S. museum or gallery and, for a variety of reasons, he wanted to transfer the painting to his spouse, who is also a non-resident alien. Let’s assume for the sake of argument that the painting was worth $50 million. Because the gift was from a non-resident alien to his non-citizen spouse, and the property was tangible property located or situated within the United States at the time of the transfer, this transfer would have been subject to tax the U.S. gift tax regime, at a tax rate of up to 40%. WHAAAAATTTTT???!!!

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Topics: estate tax, Tax, IRS, transfer tax

Building the New Berlin Wall: Treasury's Anti-Inversion Regulations

Posted by Joseph B. Darby III on Jun 10, 2016 9:23:03 AM

The Treasury no doubt felt that it could chalk one up in the win column early in April 2016 when, following its release of a veritable carpet bombing of new regulations designed to blow up inversion transactions, the primary target, Pfizer Inc., chose to wave the white flag and cancel—at least for the time being—its efforts to merge with Allergan PLC. 

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Topics: IRS, Tax, Inversion Transactions, U.S. Treasury

Forms Over Substance: IRS Information Reporting Surges

Posted by Joseph B. Darby III on Feb 26, 2016 11:29:25 AM

Once upon a time, the United States federal income tax laws were largely about determining your federal taxable income and then calculating and paying the appropriate amount of income tax. How quaintly old-fashioned that era seems today. 

Increasingly, the IRS is interested in much more than just your income taxes (although you still need to pay your taxes, too). These days, the IRS is also busy chasing a wide range of information, which is required to be reported timely on a remarkable – and often redundant – array of IRS returns. Typically, these returns demand stunningly detailed information covering a broad array of business and personal activities and assets. 

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Topics: IRS, FBAR, Foreign Assets

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The Tax & Sports Update provides timely updates and cutting-edge commentary on all issues affecting U.S. taxation, and, of course, an always humorous take on sports!

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