The Resource Considerations in relying on a CLN as an alternative to the OVDP and SFOP

Considerations in relying on a CLN as an alternative to the OVDP and SFOP

Label
Considerations in relying on a CLN as an alternative to the OVDP and SFOP
Title
Considerations in relying on a CLN as an alternative to the OVDP and SFOP
Creator
Subject
Language
eng
Summary
For most U.S. citizens residing outside the United States who have not been totally tax compliant, the Offshore Voluntary Disclosure Program (OVDP) and Streamlined Filing Offshore Procedure (SFOP) offer opportunities to address a broad range of past noncompliance. The OVDP and SFOP were initiated by the Internal Revenue Service to process large numbers of somewhat similarly situated taxpayers. The stated objective of these programs is to "bring taxpayers that have used undisclosed foreign accounts and assets, including those held through undisclosed foreign entities, to avoid or evade tax into compliance with United States tax and related laws." Even taxpayers who have failed to file U.S. income tax returns are eligible to participate in either program. Renunciation of U.S. citizenship may be attractive to taxpayers who do not wish to deal with an ongoing tax compliance burden. Some would be expatriates may have already relinquished U.S. citizenship as the result of certain actions taken in the past. For those taxpayers, U.S. tax compliance obligations - past, current, and future - simply may not exist. However, the more compelling reason to confirm prior relinquishment of U.S. citizenship is to avoid the U.S. exit tax either in its current incarnation in Section 877A or its prior incarnation in Section 877. Although current renunciation of U.S. citizenship is not a solution to address past noncompliance, the particular individual confronting U.S. tax compliance obligations may have lost U.S. citizenship sufficiently far in the past as a result of an act of relinquishment so as to obviate the need for any U.S. filing obligations. Individuals who believe their U.S. citizenship has been lost as a result of an act of relinquishment can request a Certificate of Loss of Nationality (CLN) from the U.S. Department of State
Citation source
In: Tax management international journal. - Arlington. - Vol. 45 (2016),
http://library.link/vocab/creatorName
Ward, R.E
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • tax compliance
  • citizenship
  • nationality
Label
Considerations in relying on a CLN as an alternative to the OVDP and SFOP
Instantiates
Publication
Label
Considerations in relying on a CLN as an alternative to the OVDP and SFOP
Publication

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