Prose by Tax Pros

The IRS is now carrying out various enforcement campaigns. This has increased interest by taxpayers in pro-actively approaching the IRS to resolve matters on the most favorable terms possible. The IRS offers multiple programs designed to allow taxpayers to rectify specific types of non-compliance, but it has just one general program covering all types of violations, even those involving willful or possibly criminal wrongdoing. This program, called the updated voluntary disclosure practice (“UVDP”), was introduced by the IRS in 2018 and later modified in 2020 and 2022. This article explains the worldwide tax and information-reporting duties of U.S. persons, summarizes the current IRS programs available, and analyzes the five-year evolution of the UVDP. Read the full article here. About Hale E. Sheppard HALE E. SHEPPARD, Esq. (B.S., M.A., J.D., LL.M., LL.M.T.) is a Shareholder in the Tax Controversy Section of Chamberlain Hrdlicka and Chair of the International Tax Group.

  Certain U.S. individuals who cease their relationship with the United States must pay an “exit tax.” One major problem is that some taxpayers intentionally fail to file Form 8854 (Initial and Annual Expatriation Statement) to notify the IRS of their departure, keep a low profile for a few years, and thus dodge the exit tax. Other taxpayers, particularly so-called accidental Americans, do not maintain U.S. tax compliance or properly expatriate for less nefarious reasons. The current Presidential Administration has suggested changes for both categories of taxpayers. This article analyzes the exit tax, an IRS relief program for individuals who incorrectly expatriated in the past, and pending proposals. Read the full article here. About Hale E. Sheppard HALE E. SHEPPARD, Esq. (B.S., M.A., J.D., LL.M., LL.M.T.) is a Shareholder in the Tax Controversy Section of Chamberlain Hrdlicka and Chair of the International Tax Group.