Tag Archives: voluntary disclosure

IRS Offshore Voluntary Disclosure Program 2014

February 05, 2014  |   Posted by :   |   Tax Evasion,Voluntary Disclosure   |   0 Comments

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. In […]

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IRS Voluntary Disclosure 2013: An Update

October 05, 2013  |   Posted by :   |   Tax Evasion,Unreported Income,Voluntary Disclosure   |   0 Comments

Two recent cases demonstrate the great risk attendant to the IRS offshore Voluntary Disclosure Program (2012-forward) (“OVDP”). In the Bank Leumi case, dozens of U.S. taxpayers with accounts at Bank Leumi were in 2013 peremptorily disqualified from the IRS OVDP without explanation. The IRS has recently reversed this position and according to tax counsels have […]

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Voluntary Disclosure – Early History

May 28, 2013  |   Posted by :   |   Voluntary Disclosure   |   0 Comments

A tax crime is complete on the day the false return was filed. Between 1945 and 1952, the IRS had a “voluntary disclosure” policy under which a taxpayer who failed to file a return or declare his full income and pay the tax due could escape criminal prosecution through voluntary disclosure of the deficiency, (so […]

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IRS Eyes U.S. Accounts at Caribbean Bank

May 28, 2013  |   Posted by :   |   Tax Evasion,Voluntary Disclosure   |   0 Comments

“IRS eyes U.S. accounts at Caribbean bank” by Nanette Byrnes, Reuters, 4/30/13 U.S. Department of Justice said April 30, 2013 that a federal court has authorized the IRS to seek information on U.S. taxpayers who may have accounts at Canadian Imperial Bank of Commerce, First Caribbean International Bank (FCIB). The U.S. Justice Department said a […]

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Voluntary Disclosure – Yes or No?

May 15, 2013  |   Posted by :   |   Tax Evasion,Voluntary Disclosure   |   0 Comments

by Sanford Passman, Esq. and Gary S. Wolfe The Internal Revenue Service (“IRS”) Offshore Voluntary Disclosure Program (2012) is offered by the IRS to American taxpayers who may be in violation of U.S. tax laws for a myriad of reasons. Given the enormous sums of money which are spirited to offshore tax havens throughout the world, […]

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IRS Voluntary Disclosure Initiative – Post-UBS Agreement

May 08, 2013  |   Posted by :   |   Tax Evasion,Voluntary Disclosure   |   0 Comments

On 3/23/09, the IRS issued three memoranda regarding the voluntary disclosure of offshore accounts with the following key points: 1. The IRS was prioritizing audit examinations and investigations of abusive offshore transactions designed to evade the payment of U.S. taxes; 2. The Criminal Investigation Division (“CID”) of the IRS was made responsible for initially screening […]

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IRS Tax Evasion – Offshore Accounts

Under Treasury Department Circular #230 (Rev. 8/11), Title 31 Code of Federal Regulations, Subject A, Part 10 (published June 3, 2011), Section 1021 requires a tax practitioner who knows that the client has not complied with U.S. revenue laws, or made an error or omission in a tax return, to promptly advise the client of […]

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Tax Evasion and the U.S. Mail

May 02, 2013  |   Posted by :   |   Tax Evasion,Unreported Income,Voluntary Disclosure   |   0 Comments

UBS and Beda Singenberger Beda Singenberger of Zurich Switzerland, who ran Sinco Treuhand, a wealth management and tax advisory business in Switzerland, disclosed a list of U.S. clients (hiding money in Switzerland) in the mail, which was retrieved by U.S. authorities. Over an eleven year period, Singenberger helped sixty people in the U.S. hide $184M […]

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IRS Offshore Voluntary Disclosure Program – OVDP

April 26, 2013  |   Posted by :   |   Voluntary Disclosure   |   0 Comments

In January, 2012 the IRS began their third Offshore Voluntary Disclosure Program (OVDP); the two prior initiatives (2009 OVDP, which ran from 3/23/09 through 10/15/09, and 2011 OVDI which ran from 2/8/11 through 9/9/11). The OVDP was established to encourage taxpayers to disclose previously undisclosed foreign offshore accounts, and undisclosed income from offshore accounts. U.S. […]

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IRS OVDP – Tax Compliance 2012

April 26, 2013  |   Posted by :   |   Tax Evasion,Voluntary Disclosure   |   0 Comments

The IRS/OVDI program requires: 1. Filing complete and accurate Form 1040(x) amended federal income tax returns for all tax returns covered by the voluntary disclosure, with applicable schedules detailing the type and amount of previously unreported income from the account or entity (Schedule B for interest and dividends, Schedule D for capital gains and losses, […]

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