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Modified IRS remediation program: Are you wilful?
Published on 01 May 19 by "TAXATION IN AUSTRALIA" JOURNAL ARTICLE
In late 2018, the Internal Revenue Service (IRS) closed the Offshore Voluntary Disclosure Program and has since released an updated voluntary disclosure program with significant operational and procedural changes that will impact taxpayers seeking to enter the program. Members of wealthy Australian families who relocate to the US, or members of US-based families moving to Australia, are often doing so without being fully aware of the stringent reporting and filing requirements on foreign assets, financial accounts and asset holdings they will be subject to. This invariably results in taxpayers seeking to enter into remediation programs to limit or mitigate penalty exposure on misreporting and non-compliance with the IRS. Deciding which program is best for a taxpayer is imperative and can now result in further penalty exposure where a lack of analysis of the facts and circumstances surrounding the non-compliance is conducted. The question remains: have you been wilful?
Author profiles
Peter Harper
Peter is the CEO of the Asena Group, a multi-family office. He has spent most of his career advising foreign-owned, privately held businesses and family offices on global structuring and US inbound investment. Peter's core focus is extracting value for family offices, and he believes in a “stakeholder framework” to corporate taxation. The “stakeholder framework” encompasses the development of a tax strategy that facilitates value for families, rather than for the portfolio companies that they invest in or manage. - Current at 20 April 2020
Aman Mullee
Amanvir is an Australian tax lawyer and an expert in US–Australian cross-border tax issues. Amanvir has experience working on complex international M&A transactions in his previous position in deal advisory tax for a Big 4 accounting firm. Amanvir has completed his CTA level 2 and is a qualified solicitor in New South Wales. Amanvir specialises in advising privately held businesses on international tax issues, and entrepreneurs and executives on the taxation impact of relocating between the US and Australia. Amanvir has advised listed companies, entrepreneurs and family offices on a broad range of international tax issues, including to income tax, capital gains tax and estate planning.Current at 1 March 2017
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