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Daily Tax Report Quotes Scott Michel on New Offshore Disclosure Program for U.S. Taxpayers

June 4, 2014, Daily Tax Report

Scott D. Michel was quoted by the Daily Tax Report regarding the Internal Revenue Service's forthcoming new disclosure program. The program may allow U.S. taxpayers, especially longtime non-residents, with undisclosed offshore accounts who are not willfully evading taxes, to come into compliance and face reduced penalties. However, the timing of the announcement may create uncertainties for non-resident taxpayers who will need to file tax returns by June 16 and all citizens and residents as to Foreign Bank and Financial Account Reports (FBARs), due by June 30. For the full article, please visit the Daily Tax Report website (subscription required).
Excerpt taken from the article. 

Analysts cautiously welcomed the news, stating that more details on the program are necessary before it can be fully supported. "Any liberalization of the program's requirement for non-willful taxpayers and for non-resident taxpayers would be most welcome and would, in my view, dramatically increase the intake that the IRS would see into these programs," Scott Michel, a member of Caplin & Drysdale Chartered in Washington, told Bloomberg BNA June 3.

However, he said that the timing of the program's official unveiling was placing nonresident taxpayers and their tax advisers in a difficult situation with regard to deadlines for filing 2013 tax return extensions by June 16 and filing Foreign Bank and Financial Account Reports (FBAR) by June 30.

"There's a real timing issue with clients coming to see tax professionals at this point during the year and having to evaluate their options when they're under the gun of these looming deadlines," he said.

Taxpayers and tax professionals would be best served if the IRS would announce the new program quickly, "so the tax community can filter them in considering what advice to give noncompliant taxpayers approaching tax practitioners around the world about their U.S. issues," he said.


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