According to the BNA the IRS will soon announce several changes to
the streamlined version of the Offshore Voluntary Disclosure Program,
but won’t change the policies behind eligibility for the program, two
agency officials said September 20, 2014.
For domestic participants the IRS will consider only the taxpayer’s
personal financial interests in determining eligibility, not accounts
for which taxpayers only have signature authority.
The agency will make it clear that domestic participants will have to
include, in the penalty base, foreign assets that they may have already
reported on a Form 5471 or a Form 3520.
These comments were made at the fall meeting of the American Bar Association in
Denver by Jennifer Best, senior adviser to the deputy commissioner of
the Large Business & International Division & John McDougal,
special trial attorney for the Small Business/Self-Employed Division.
Unfortunately they did not make comments about if they would include a new guidance that would provide clarification on what "non-willful or willfully blind means".
No comments:
Post a Comment
Note: Only a member of this blog may post a comment.