Of course, the taxpayer can argue that FBAR penalties are inappropriate after the opt-out election is made.
FORBES: FATCA Blues? Opt Out Of IRS Offshore Program
It is clear the opt-out election is irrevocable and is typically made after the IRS has calculated a proposed miscellaneous offshore penalty.
For 2009 Offshore Volunteer Disclosure Initiative (OVDI) opt-outs, the IRS took approximately 550 days to close the case after the opt-out election.
Individual states would have until 2014 to decide whether they wanted to opt out, according to Reid, a Nevada Democrat facing tough re-election prospects next year.
CNN: STORY HIGHLIGHTS
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