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Offshore Voluntary Disclosure Initiative

Streamlined offshore account compliance guidance for Canadian retirement plan participants

Streamlined offshore account compliance guidance for Canadian retirement plan participants

IRS has added new FAQs to its website on the IRS streamlined offshore account compliance program, that include guidance to participants in Canadian retirement plans.  Click here for the Streamlined Filing Compliance Procedures for U.S. Taxpayers Residing in the United States Frequently Asked Questions and Answers (Updated Jan. 7, 2016) (“Domestic Q&As”).  Click here for […]

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IRS National Tax Advocate: problems remain with the IRS offshore voluntary disclosure program

IRS National Tax Advocate: problems remain with the IRS offshore voluntary disclosure program

National Taxpayer Advocate (NTA) Nina Olson has released her annual report to Congress, and it highlights flaws with the IRS offshore voluntary disclosure program (OVDP). According to the NTA, the flaws do not bode well for fairness and justice in IRS’s implementation of future settlement programs and undermine voluntary taxpayer compliance. The NTA has recommended […]

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September 15, 2014 – Last Day For Category 2 Banks to Disclose – – Offshore Unreported Income

September 15, 2014 – Last Day For Category 2 Banks to Disclose – – Offshore Unreported Income

As widely reported, Banks have been moving and dodging the U.S. Department of Justice and the opportunity to participate in some version of “let’s make a deal,” so the Bank will not be prosecuted criminally or assessed civil penalties.  The latest is the upcoming deadline imposed by the Department of Justice on Category 2 Banks. […]

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2014 – New IRS Offshore Voluntary Disclosure Program (OVDP), Amnesty, and Streamlined Compliance Filing Procedures

2014 – New IRS Offshore Voluntary Disclosure Program (OVDP), Amnesty, and Streamlined Compliance Filing Procedures

On June 18, 2014, the IRS announced a new sweeping and revised Offshore Voluntary Disclosure Program, as well as the new “Streamlined Compliance Filing Procedures.”  We have recently blogged on these updated changes as follows: IRS announces changes to offshore account compliance program; IRS FAQs clarify changes to offshore voluntary disclosure program and transition rules; […]

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IRS FAQs clarify changes to offshore voluntary disclosure program and transition rules

IRS FAQs clarify changes to offshore voluntary disclosure program and transition rules

Click here for the revised frequently asked questions (FAQs) on the offshore voluntary disclosure program (OVDP). Click here for FAQs on the transition rules. In conjunction with its announcement of changes to the offshore voluntary disclosure program (OVDP), IRS has issued a series of revised frequently asked questions (FAQs) providing detailed guidance on the newly […]

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OVDP & New Streamlined Compliance Filing Procedures: July 1, 2014 Deadline — Traps for the Unwary & Questions Remain

OVDP & New Streamlined Compliance Filing Procedures:  July 1, 2014 Deadline — Traps for the Unwary & Questions Remain

I am glad the IRS announced, on June 18, 2014, changes to the existing Offshore Voluntary Compliance Program.  Many of the changes were long overdue and so I must commend the IRS for the changes, particularly with the adoption of the new Streamlined Compliance Filing Procedures, for those folks who acted non-willfully.  However, there is […]

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IRS announces changes to offshore account compliance program

IRS announces changes to offshore account compliance program

IR 2014-73; Fact Sheet 2014-6, 06/18/2014; Fact Sheet 2014-7, 06/18/2014. Click here for the statement of IRS Commissioner John Koskinen on changes to IRS’s offshore account compliance program. As previewed by IRS Commissioner John Koskinen a couple weeks back, IRS has announced a number of changes that it is making to its offshore account compliance […]

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Washington Alert – IRS report on filing season, and latest on offshore tax abuses, IRS’s 2009 Offshore Voluntary Disclosure Program (OVDP)

Washington Alert – IRS report on filing season, and latest on offshore tax abuses,  IRS’s 2009 Offshore Voluntary Disclosure Program (OVDP)

By the conclusion of thee third week of the current filing season, IRS had received approximately one-third of the individual income tax returns that it expects to receive during all of 2014, the agency announced on Feb. 27. (IR 2014-20) As of Feb. 21, IRS had processed 98% of the 49.6 million returns it had […]

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U.S. charges Swiss asset manager in offshore tax fraud case

U.S. charges Swiss asset manager in offshore tax fraud case

NEW YORK (Reuters) – U.S. prosecutors on Thursday announced they indicted Peter Amrein, a Swiss asset manager, on charges that he assisted U.S. taxpayers in evading millions in taxes by hiding money in offshore trusts at multiple Swiss banks. A copy of the sealed indictment is here. Prosecutors accuse Amrein, who worked at an unidentified […]

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2014: Court of Appeals for Seventh Circuit finds no relief for taxpayer’s criminal liability in Offshore Voluntary Disclosure Program

2014: Court of Appeals for Seventh Circuit finds no relief for taxpayer’s criminal liability in Offshore Voluntary Disclosure Program

The Seventh Circuit Court of Appeals in Simon v. U.S., (7th Cir. August 15, 2013), 112 AFTR 2d ¶2013-5205, has rejected arguments made based on the Offshore Voluntary Disclosure Program (OVDP) by a taxpayer who was convicted of filing false income tax returns, failing to file Report of Foreign Bank and Foreign Accounts (FBARs), mail […]

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2014: IRS Warns Taxpayers Voluntarily Coming Into Offshore Compliance To Be Truthful

2014:  IRS Warns Taxpayers Voluntarily Coming Into Offshore Compliance To Be Truthful

Editor’s Note:  This is a re-blog for January 2014:  IRS warns taxpayers voluntarily coming into offshore compliance to be truthful [ABA Tax Section meeting San Diego 2/18/2012]: The IRS is aggressively using intelligence gathered from the agency’s Offshore Voluntary Compliance Program to study the movement of undisclosed funds abroad and to deter tax avoidance, an […]

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2014: The IRS’s Offshore Voluntary Disclosure Programs Discourage Voluntary Compliance by Those Who Inadvertently Failed to Report Foreign Accounts

2014: The IRS’s Offshore Voluntary Disclosure Programs Discourage Voluntary Compliance by Those Who Inadvertently Failed to Report Foreign Accounts

Editor’s Note:  This is a re-blog in January 2014:  As noted by Nina Olsen, in her National Taxpayer Advocate Delivers Annual Report to Congress, one of the most serious problems of the IRS is the IRS’s Offshore Voluntary Disclosure Programs Discourage Voluntary Compliance by Those Who Inadvertently Failed to Report Foreign Accounts.    This article […]

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2014: IRS Voluntary Disclosure – Option #2 – Participate “Somewhat” But Not Completely: Options for Taxpayers Contemplating the Program

2014:  IRS Voluntary Disclosure – Option #2 – Participate “Somewhat” But Not Completely:  Options for Taxpayers Contemplating the Program

NOTE: JUNE 18, 2014 – – The IRS came out with NEW and REVISED Rules and Procedures for the Offshore Voluntary Disclosure Program and the Streamlined Compliance Filing Procedures. Here are the links to two articles which are MUST reads: 1. 2014 – New IRS Offshore Voluntary Disclosure Program (OVDP), Amnesty, and Streamlined Compliance Filing […]

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2014: IRS and DOJ Alert: Will the New IRS Offshore Voluntary Disclosure Initiative Be Fair?

2014: IRS and DOJ Alert:  Will the New IRS Offshore Voluntary Disclosure Initiative Be Fair?

Editor’s Note:  This is a re-blog for January 2014.  The IRS recently announced the”third” wave of tax amnesty, as reported on this blog Here We Go Again – IRS Announces Third Offshore Voluntary Disclosure Program.  The National Taxpayer Advocate recently issued it’s 2011 Annual Report to Congress, concerning the harm to taxpayers, as reported on […]

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2014: Here We Go Again — IRS Announces Third Offshore Voluntary Disclosure Program

NOTE: JUNE 18, 2014 – – The IRS came out with NEW and REVISED Rules and Procedures for the Offshore Voluntary Disclosure Program and the Streamlined Compliance Filing Procedures. Here are the links to two articles which are MUST reads: 1. 2014 – New IRS Offshore Voluntary Disclosure Program (OVDP), Amnesty, and Streamlined Compliance Filing […]

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2014: IRS Voluntary Disclosure – To Participate or Not Participate, That is the Question: Options for Taxpayers Contemplating the Program

2014:  IRS Voluntary Disclosure – To Participate or Not Participate, That is the Question:  Options for Taxpayers Contemplating the Program

NOTE: JUNE 18, 2014 – – The IRS came out with NEW and REVISED Rules and Procedures for the Offshore Voluntary Disclosure Program and the Streamlined Compliance Filing Procedures. Here are the links to two articles which are MUST reads: 1. 2014 – New IRS Offshore Voluntary Disclosure Program (OVDP), Amnesty, and Streamlined Compliance Filing […]

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2014: Last chance to enter into IRS “amnesty” program, Offshore Voluntary Disclosure Program?

2014: Last chance to enter into IRS “amnesty” program, Offshore Voluntary Disclosure Program?

NOTE: JUNE 18, 2014 – – The IRS came out with NEW and REVISED Rules and Procedures for the Offshore Voluntary Disclosure Program and the Streamlined Compliance Filing Procedures. Here are the links to two articles which are MUST reads: 1. 2014 – New IRS Offshore Voluntary Disclosure Program (OVDP), Amnesty, and Streamlined Compliance Filing […]

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Tax Tips: How Long Should I Keep My Tax Records?

Tax Tips:  How Long Should I Keep My Tax Records?

Editor’s Note:  This is a repeat of my blog article which appeared on June 21, 2012.   If I had a dollar for every time that question has been posed to me over the years, . . . The answer is “it depends.”  The article posted in the L.A. Times generated my blog on this subject.  […]

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Offshore tax-dodger dragnet widens with U.S.-Swiss bank deal – lawyers

Offshore tax-dodger dragnet widens with U.S.-Swiss bank deal – lawyers

WASHINGTON, Sept 3 (Reuters) – The U.S. government, stepping up its pursuit of American offshore tax dodgers worldwide, stands to gather an abundance of leads through a bank information-sharing deal between the United States and Switzerland, tax lawyers said on Tuesday. The pact last week marked a turning point in a lengthy dispute between Bern […]

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Court of Appeals for Seventh Circuit finds no relief for taxpayer’s criminal liability in Offshore Voluntary Disclosure Program

Court of Appeals for Seventh Circuit finds no relief for taxpayer’s criminal liability in Offshore Voluntary Disclosure Program

The Seventh Circuit Court of Appeals in Simon v. U.S., (7th Cir. August 15, 2013), 112 AFTR 2d ¶2013-5205, has rejected arguments made based on the Offshore Voluntary Disclosure Program (OVDP) by a taxpayer who was convicted of filing false income tax returns, failing to file Report of Foreign Bank and Foreign Accounts (FBARs), mail […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney