Virginia residents who have not timely disclosed their foreign financial assets to the Internal Revenue Service (IRS) have one less option than they did a year ago. This is because the IRS’s Offshore Voluntary Disclosure Program (OVDP) ended on September 28, 2018. While there is a new program that has taken the place of the OVDP, this new program is different from the OVDP in many important respects. As a result, anyone needing to catch up on their foreign financial disclosures should speak with a Virginia OVDP lawyer as soon as possible.

If you have unreported offshore bank accounts, you may be aware that you can disclose these accounts to the IRS while minimizing your penalties and criminal exposure. However, you may also be inclined to refrain from disclosing these accounts immediately. That said, the question is: Disclose now or later?

As a U.S. taxpayer, you have the right to challenge any IRS tax bill that you believe is either unfair or inaccurate. However, any such challenge will need to comply with strict guidelines and procedures. This is not something that is advisable for the taxpayer to do on their own. Legal representation will be necessary.

Any U.S. taxpayer is expected to comply with IRS rules and regulations, including in situations where a U.S. affiliated person lives abroad. There are strict rules in the United States for taxpayers who have financial accounts outside of this country, even if those taxpayers are living in a foreign jurisdiction and simply have an account in a bank where they live. Depending on the account's value, requirements may include filing an annual Report of Foreign Bank and Financial Account (FBAR). Taxpayers may also be required to disclose foreign assets by filing Form 8938 with their tax returns.

Managing Partner Kevin E. Thorn was recently asked by a DC news source to comment on former Trump campaign chairman Paul Manafort’s trial taking place in a federal court in Alexandria, Virginia.