International tax & business 2019

Modified IRS remediation program: Are you wilful?

Source: Taxation In Australia Journal Article

Published Date: 1 May 2019


In late 2018, the Internal Revenue Service (IRS) closed the Offshore Voluntary Disclosure Program and has since released an updated voluntary disclosure program with significant operational and procedural changes that will impact taxpayers seeking to enter the program. Members of wealthy Australian families who relocate to the US, or members of US-based families moving to Australia, are often doing so without being fully aware of the stringent reporting and filing requirements on foreign assets, financial accounts and asset holdings they will be subject to. This invariably results in taxpayers seeking to enter into remediation programs to limit or mitigate penalty exposure on misreporting and non-compliance with the IRS. Deciding which program is best for a taxpayer is imperative and can now result in further penalty exposure where a lack of analysis of the facts and circumstances surrounding the non-compliance is conducted. The question remains: have you been wilful?

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International tax & business 2019

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