Tax Law News and Information Straight from The Tax Lawyer
Federal law requires U.S. taxpayers with more than $10,000 total in foreign accounts to report those accounts on their tax return. Those that fail to do so may face an audit, substantial financial penalties, criminal prosecution, and imprisonment. In an effort to find such accounts the U.S. Department of Justice (DOJ) recently announced a tax deal with Switzerland.
In addition to the formal Offshore Voluntary Disclosure Program, the IRS offers Streamlined Filing Compliance Procedures for certain qualified taxpayers.
Before a taxpayer even makes a submission to the Offshore Voluntary Disclosure Program, he or she must successfully complete a pre-clearance phase.
In addition to the numerous civil penalties potentially facing taxpayers who fail to participate in the Offshore Voluntary Disclosure Program, there are also some serious criminal charges that may result if the IRS
The IRS Criminal Investigation division has a longstanding practice of considering a taxpayer’s timely, accurate, and complete voluntary disclosure in determining whether or not to pursue criminal prosecution against the taxpayer.
A previous article on this topic addressed the civil penalties potentially applying to taxpayers who qualify for the Offshore Voluntary Disclosure Program but fail to apply.