Event 14 Oct. 2022
Curtis Provides Capacity Training to the Government of Uganda
more
Event 21 Sep. 2022
Kalidou Gadio Speaks at AIEN 2022 International Energy Summit
Event 06 Jun. 2023
Partner Borzu Sabahi Speaks on Panel in Tashkent Law Spring International Legal Forum in the Republic of Uzbekistan
News 15 May. 2023
Curtis represents e-commerce retailer in its fight to recover monies withheld by PayPal, the global payment giant
Event 08 May. 2023
Partner Irene Petrelli to Participate in ICC YAAF Event
News 02 May. 2023
Curtis Italy with DeA Capital in the Acquisition of Magic S.r.l
Event 07 Jun. 2023
Elisa Botero Speaks on Latin America’s H2 Potential at AIEN’s International Energy Summit
Event 23 May. 2023
Partners Luciana Ricart and Fernando Tupa Will Teach a Workshop on Hearings in Investment Arbitration for Arbanza School of Arbitration’s Online Program
Event 03 May. 2023
Dr. Borzu Sabahi to Speak at ICSID-ADGM Joint Conference: Investment Protection and Armed Conflict
Event 19 Mar. 2023
Sebastiano Nessi speaks at Bahrain Business and Legal Landscape Conference
Event 01 Jun. 2023
Curtis Environmental Chair Charles Howland to Moderate Panel Discussion on Latest Developments in Environmental Due Diligence at ABA Masterclass on Environmental Transactions
News 25 May. 2023
Curtis Files SCOTUS Amicus Brief for Distinguished Law Professors in First Amendment Retaliatory Arrest Case
News 06 Mar. 2023
Russia Sanctions at the First Anniversary: An Overview of Current Sanctions in the US, UK, and EU and How Global Companies Can Navigate Evolving and Conflicting Sanctions Regimes
Client Alert 30 Aug. 2022
The EU Adopts the “Maintenance and Alignment” Sanctions Package
Client Alert 24 Jun. 2021
Update on Virtual Notarization (Executive Order 202.7) During the COVID-19 (Coronavirus) Pandemic (Updated: June 24, 2021) — U.S. Insight
Update on Virtual Witnessing (New York Executive Order 202.14) During The COVID-19 (Coronavirus) Pandemic (Updated: June 24, 2021) — U.S. Insight
Publications August 2009
In response to the large volume of requests that it received, on July 29, 2009, the IRS issued an optional form (http://www.irs.gov/compliance/enforcement/article/0,,id=205909,00.html) for taxpayers who want to make a voluntary disclosure of foreign bank accounts or assets. A taxpayer may complete the form and send it to the IRS at the appropriate address listed on the website above. The form must be sent (and should be received by the IRS) before September 23, 2009 in order to be eligible for the amnesty program that the IRS announced on March 26, 2009. The amnesty program provides a favorable penalty framework for failure to file Form TD F 90-22.1 ('FBAR'). The favorable 20% penalty under the amnesty program is available only if the IRS accepts a taxpayer's voluntary disclosure. Generally, a voluntary disclosure will not be accepted by the IRS unless the disclosure is received by the IRS before it has initiated an examination or investigation of the taxpayer or received information alerting it of the taxpayer's noncompliance. Therefore, a taxpayer interested in the amnesty program should make a voluntary disclosure as early as possible.
The questions on the form include personal identifying information, the source of funds for the offshore accounts or assets, an estimate of the annual range of the highest aggregate value of the accounts or assets, an estimate of the potential unreported income from the accounts, a list of the financial institutions and the countries in which the institutions are located, a list of the persons affiliated with the accounts, the purpose for establishing the accounts or assets, the dates the accounts were opened/closed, points of contact at the financial institutions, and an explanation of all face-to-face meetings and other communications with the institutions, independent advisors or investment managers regarding the accounts or assets.
The taxpayer must sign the form under 'penalties of perjury' and certify that the taxpayer is willing to cooperate with the IRS, including in assessing income tax liabilities and making good faith arrangements to pay all taxes, interest and penalties associated with the disclosure. Sending the form only initiates the process and does not mean that the IRS will accept the voluntary disclosure. The IRS has stated that, if the form is fully completed, it generally will have 'the information we need to indicate to the individual whether they're eligible to make a voluntary disclosure.'
To ensure compliance with requirements imposed by the IRS, we inform you that, unless explicitly provided otherwise, any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.
Marco A. Blanco
Partner
We use cookies on our website to enhance your browsing experience, match your interests and assess our website performance. We do not share information with any third-party for marketing purposes. Please view our privacy policy to learn more about the use of cookies on our website. By continuing to browse our website, you consent to our use of cookies.