Page 31 - Disclosure Program News Today

The "Report of Foreign Bank and Financial Accounts" (FBAR) penalty has been the subject of much litigation. This Holland & Knight alert focuses on the non-willfulness element of 31...

United States citizens and residents[i] are subject to federal income tax on their worldwide income. For example, even if a United States citizen permanently relocates to a foreign...

Federal district courts around the country are handling a torrent of litigation on an unsettled and costly question in FBAR litigation — how should penalties for non-willful violations...

In the world of Voluntary Disclosure, it is well-established amongst experienced tax counsel that submitting to the IRS Voluntary Disclosure Program…

The Internal Revenue Service continues to move full steam ahead on enforcement matters involving noncompliance with FBAR reporting (Foreign Bank and…

At the end of 2018, the Internal Revenue Service discontinued the Offshore Voluntary Disclosure Program (OVDP). Then, at the end of 2018 and early…

On November 30, 2021, the Fifth Circuit parted ways with the taxpayer friendly decision of the Ninth Circuit that non-willful penalties are capped at $10,000 per FBAR filing instead of...

On November 8, 2021, the U.S. Department of Health and Human Services Office of Inspector General (“OIG”) released a revised Provider Self-Disclosure Protocol, renamed Health Care Fraud...

On 29 October 2021, the Government of the Republic of Indonesia has officially promulgated Law No. 7 of 2021 on Harmonization of Tax Regulations (“Law…

The Department of Health & Human Services Office of the Inspector General OIG issued a handful of changes to its Provider Self-Disclosure Protocol and renamed the long-standing guidance document to OIG’s Health Care Fraud Self-Disclosure Protocol.