IRS Offshore Voluntary Disclosure Program 2014

Kathy Keneally, U.S. Assistant Attorney General, advised that 106 Swiss banks have agreed to non-prosecution agreements with the U.S. government and will provide data on those U.S. taxpayers who hid assets in these Swiss banks. These Swiss banks are sending letters to these U.S. customers advising them to enter the IRS Voluntary Disclosure program.

IRS Offshore Voluntary Disclosure

In my book, “Offshore Tax Evasion: IRS Offshore Voluntary Disclosure Program,” I advised against entering the IRS/OVDP for the following reasons:

1. No transactional or use immunity (i.e. Ty Warner case).

2. Waiver of 5th Amendment Right of Self-Incrimination, 4th amendment Right Against Unreasonable Searches, 8th Amendment Right Against Excessive Fines.

3. Waiver of Statute of Limitations Defenses.

For those interested in an alternate tax compliance strategy please send me an email with your questions to:

For complete article please see “Swiss Bank Secrecy Succumbs To U.S. Tax Enforcers.


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