irstaxlitigation Blog

New Relaxed Installment Agreement Rules — Form 9465-FS

Link:   The IRS has recently announced a set of relaxed rules on setting up Installment Agreements for individuals owing between $25,000 – $50,000.  The IRS will no longer require a financial Collection Information Statement (Form 433-A or Form 433-F ),  for these taxpayers and will allow them to setup streamlined installment agreements.  This […]

2012 Offshore Voluntary Disclosure Initiative (OVDI) — To Opt-Out or Opt-In to the Program?

Link: Attached is a very interesting article from Bloomberg, which discussed the recent OVDI programs for FBAR compliance.  Nina Olson, National Taxpayer Advocate, discusses how the program is highly beneficial to those who were intending to hide assets overseas.  However, the program is looked at by many as punitive to those who only negligently […]

2012 Offshore Voluntary Disclosure Initiative Announced (FBAR Compliance)

Link:,,id=252162,00.html?portlet=108   The IRS has announced that it is extending the Offshore Voluntary Disclosure Initiative Program (“OVDI”) into 2012.  This extension is due to the sucess of the last 2 programs, which brought a significant number of taxpayers into compliance with their reporting obligations.   Any United States person, living in the U.S. or […]

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FBAR Enforcement

An interesting article about IRS initiatives in Switzerland: For U.S. citizens who have an aggregate of $10,000 or more in foreign bank accounts, there is a requirement to disclose this information to the IRS, by filing an FBAR with the Department of Treasury.