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Showing posts from January, 2016

What You Need to Know About the Indonesia-US FATCA Agreement

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Compliance Awakens

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Notes from the Florida International Tax Conference in Miami on January 8

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David Horton, acting deputy commissioner (international), IRS Large Business and International Division, who spoke at the annual Florida International Tax Conference in Miami on January 8, seems to have a more sanguine view of human nature than the assembled lawyers and accountants. Robert E. Panoff of Robert E. Panoff PA asked some government officials tough questions supplied by the audience.

Horton reported that while the IRS is still getting a steady flow of offshore voluntary disclosure program filings every month, that program has to end eventually. He anticipated that in the future, most taxpayers would get right with their tax collector and their God, so that the OVDP would no longer be necessary. Mark F. Daly, senior litigation counsel in the Justice Department Tax Division, said that Justice is getting a lot of good information from the OVDP, under which taxpayers are required to identify their financial institutions and enablers. The OVDP is turning up recalcitrant taxpaye…

Notes from the New York University Tax Controversy Forum in New York

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The United States is reluctant to punish tax cheats too heavily. They generally don't go to prison unless something else is going on (e.g., United States v. Simon, 727 F.3d 682 (7th Cir. 2013) ). So the IRS has developed a sliding scale of settlement options in the period since the UBS scandal first came to light. Nonetheless, the agency's best efforts to make penalties proportionate to taxpayer perceptions have not discouraged quiet disclosure.


At the June 5 New York University Tax Controversy Forum in New York, practitioners discussed with John McDougal, special trial attorney and division counsel with the IRS Small Business/SelfEmployed Division, and David Horton, director (international individual compliance) in the IRS Large Business and International Division, how to navigate the now-perpetual IRS offshore voluntary disclosure program and the newer options. Larry A. Campagna of Chamberlain, Hrdlicka, White, Williams & Aughtry moderated a panel that included Megan L.…