News & Insights: paul bercovici

IRS Announces Termination of 2014 Offshore Voluntary Disclosure Program


By Paul Bercovici  |  March 19, 2018

On March 13, 2018, the IRS announced that the 2014 Offshore Voluntary Disclosure Program (OVDP) will close on September 28, 2018. This program allows U.S. taxpayers who failed to report certain offshore assets - and/or the income derived from such assets - to voluntarily come into compliance with U.S. tax laws and generally avoid criminal prosecution in exchange for payment of an offshore penalty.

Tax Act puts onus on Americans to do the right thing


By Paul Bercovici  |  August 8, 2017


IRS Announces Major Changes Regarding Offshore Voluntary Disclosures


By Paul Bercovici  |  June 30, 2014

On June 18, 2014, the IRS announced significant changes to the 2012 Streamlined Program and to the 2012 Offshore Voluntary Disclosure Program. The changes to the terms of the 2012 Streamlined Program and the 2012 Offshore Voluntary Disclosure Program are designed to encourage more taxpayers who have failed to report income from offshore assets to voluntarily come forward to report the existence of such offshore assets and the income derived therefrom. According to the IRS, approximately 45,000 taxpayers have voluntarily disclosed the existence of such accounts under the terms of the various iterations of the offshore voluntary disclosure program that was first announced in 2009, and that such disclosures have resulted in the collection of approximately $6.5 billion in taxes, interest and penalties.

Marks Paneth Tax Alert: Treasury and IRS Release Final Rules on Foreign Account Reporting


By Paul Bercovici  |  March 12, 2013

The U.S. Department of the Treasury and the IRS have issued comprehensive final regulations implementing Foreign Account Tax Compliance Act (FATCA) information reporting provisions. Under the regulations, foreign financial institutions (FFIs) — including foreign banks, brokers, insurance companies and investment funds — must disclose to the IRS certain information about their U.S.-owned accounts. This article reviews the major provisions of the final regulations and the potential impact on individual taxpayers with foreign accounts.

Tax Alert: New Guidance on Streamlined Compliance Program for Delinquent Non-Resident Taxpayers


By Paul Bercovici  |  September 12, 2012

On August 31, 2012, the IRS issued additional information regarding the streamlined federal income tax return and foreign bank account reporting requirements available to certain delinquent taxpayers which was first announced on June 26, 2012 (the Streamlined Program). The Streamlined Program was created in response to the fact that many individuals had recently become aware (primarily due to increased media coverage) of their ongoing US tax filing obligations and wanted to become compliant. The Streamlined Program came into effect on September 1, 2012.