Further to our announcement that the IRS will be shutting down the Overseas Voluntary Disclosure Program, we outline below some of the penalties taxpayers may face after the September OVDP closure date: A penalty for failing to file a tax return – The penalty is 5 percent of the balance due, plus an additional 5 […]

The Internal Revenue Service issued a memorandum last month that set maximum amounts on the penalties for failure to file a foreign bank account report (“FBAR”). In addition they issued new guidance on examination procedures of determining willful and non-willful violations.  The IRS is striving to ensure effectiveness and consistency in the FBAR compliance program […]