Should I Stay or Should I Go – Part 16

Answers to the Most Frequently Asked Questions Regarding OVDP

As a tax attorney specializing in the Offshore Voluntary Disclosure Program (OVDP), nary a day goes by that I don’t get a call from a person inquiring about the OVDP. The questions asked are relatively the same. After a while, I began to make a list of the most frequently asked questions. Below are my answers to them: (continued)

XX. Does the examiner have any discretion to settle offshore voluntary disclosure cases for amounts less than the 27.5 percent offshore penalty?

No. Examiners nave no authority to negotiate a different offshore penalty. However, in limited situations, the offshore penalty can be reduced from 27.5 percent to 12.5 percent of the account value. To qualify for the reduced 12.5 percent offshore penalty, the highest aggregate balance in each of the years covered by the OVDP must be less than $ 75,000.

Next:  XXI. What if, after making a voluntary disclosure, I disagree with the application of the offshore penalty? What can I do?

In accordance with Circular 230 Disclosure

As a former public defender, Michael has defended the poor, the forgotten, and the damned against a gov. that has seemingly unlimited resources to investigate and prosecute crimes. He has spent the last six years cutting his teeth on some of the most serious felony cases, obtaining favorable results for his clients. He knows what it’s like to go toe to toe with the government. In an adversarial environment that is akin to trench warfare, Michael has developed a reputation as a fearless litigator.

Michael graduated from the Thomas M. Cooley Law School. He then earned his LLM in International Tax. Michael’s unique background in tax law puts him into an elite category of criminal defense attorneys who specialize in criminal tax defense. His extensive trial experience and solid grounding in all major areas of taxation make him uniquely qualified to handle any white-collar case.

   

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