The link to the full report in PDF format is
http://www.taxpayeradvocate.ir...
The sections dealing with OVDP are on pages 79-93, and legislative recommendations on pages 331-344. These numbers are the numbers at the bottom of each page.
I consider pages 79-93 to be excellent because they are thorough, well researched, and address key points. Some of the key stats (You should look at the tables) re: 8,851 streamline cases through 4/24/14, (apparently most of these are Canadians) and a total of 11,146 cases in the 2009 OVDP, 13,189 in the 2011 OVDP, and 6,930 cases in the 2012 OVDP (as of 9/30/2014.)
From a policy perspective, that's about 31,000 OVDP cases out of a universe of hundreds of thousands if not millions who should be filing FBARs. Clearly not a success, and I believe that the harshness of treatment for early participants, and fear of optouts has kept and will continue to keep many away.
Processing times of "only" 219 days for closed certifications and 308 days for closed optouts are far lower than the experience/reality shows .
The figures also show how low optout penalties were (granted, only those with the most favorable facts opted out.)
The TAS is proposing ceilings on FBAR penalties, both balance-based and based on previously unpaid tax. These are sorely needed.
Though the TAS only references a TNT (Tax Notes Today) article about the IRS OVDI FOIA documents, the training does assume that with few exceptions those who had not disclosed their foreign accounts were willful, and I am grateful to the TAS for combating this perception. The TNT article is at http://www.taxpayeradvocate.ir...
http://www.taxpayeradvocate.ir...
The sections dealing with OVDP are on pages 79-93, and legislative recommendations on pages 331-344. These numbers are the numbers at the bottom of each page.
I consider pages 79-93 to be excellent because they are thorough, well researched, and address key points. Some of the key stats (You should look at the tables) re: 8,851 streamline cases through 4/24/14, (apparently most of these are Canadians) and a total of 11,146 cases in the 2009 OVDP, 13,189 in the 2011 OVDP, and 6,930 cases in the 2012 OVDP (as of 9/30/2014.)
From a policy perspective, that's about 31,000 OVDP cases out of a universe of hundreds of thousands if not millions who should be filing FBARs. Clearly not a success, and I believe that the harshness of treatment for early participants, and fear of optouts has kept and will continue to keep many away.
Processing times of "only" 219 days for closed certifications and 308 days for closed optouts are far lower than the experience/reality shows .
The figures also show how low optout penalties were (granted, only those with the most favorable facts opted out.)
The TAS is proposing ceilings on FBAR penalties, both balance-based and based on previously unpaid tax. These are sorely needed.
Though the TAS only references a TNT (Tax Notes Today) article about the IRS OVDI FOIA documents, the training does assume that with few exceptions those who had not disclosed their foreign accounts were willful, and I am grateful to the TAS for combating this perception. The TNT article is at http://www.taxpayeradvocate.ir...
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