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Tag: offshore bank

> Blog > offshore bank

DOJ’s New Tactic for Busting Secret Offshore Account Holders

Posted by Wetenkamp on December 28, 2011 with 0 Comment

When the IRS offers tax relief in any form, there should be no pause or hesitation. Some offshore bank account holders who did not come forward and disclose their holdings during one of the IRS voluntary disclosure initiatives are now receiving grand jury subpoenas requiring them to turn over their bank account information. If they don’t comply then they could be held in contempt of court  which typically carries with it hefty fines and jail time. Of course, if they do comply, they may be turning over potentially damning evidence to federal prosecutors.

This is a relatively new backdoor tactic in the epic struggle between US prosecutors and foreign banks. Or perhaps this would more accurately be described as a front-door tactic because traditional investigative steps would involve the Justice Department working with the banks within the treaty process, not going directly to the bank patrons.

Anyone receiving a subpoena should immediately consult with an attorney. It is not usually something that can be dealt with alone.

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Some Results Available from IRS Amnesty Program

Posted by Wetenkamp on September 16, 2011 with 0 Comment

The opportunity to obtain tax relief and avoid criminal prosecution under the 2011 Offshore Voluntary Disclosure Initiative came to an end last week.  The results released on Thursday 9/15 seem to suggest that the 2011 initiative was not as successful as the 2009 initiative, but it is too early to tell for sure.

2009 Amnesty Program
  • 15,000 voluntary disclosures (and additional 3,000 filed late)
  • $2.2 billion collected
  • Amount collected is from 80 percent of cases now closed
2011 Amnesty Program
  • 12,000 voluntary disclosures
  • $500 million collected*
  • Percentage of closed cases likely small
*Collection of penalties and installment payments will continue in the coming months and this figure may still surpass the $2.2 billion collected under the 2009 program.

VCI-2: Amnesty for Californians

Posted by Wetenkamp on August 2, 2011 with 0 Comment

Voluntary Compliance Initiative 2 (VCI-2) is “an opportunity for taxpayers who underreported their California income tax liabilities, through the use of abusive tax avoidance transactions (ATAT) or offshore financial arrangements (OFA), to amend their returns for 2010 and prior tax years and obtain a waiver of most penalties.” The benefits of coming forward under this program are impressive: the Franchise Tax Board (FTB) waives penalties for most taxpayers and promises not to pursue them criminally. The complexities of VCI-2 are in the determination of what activities fall under the scope of “abusive tax avoidance transactions” and “offshore financial arrangements.” FTB does define each category, so this is certainly not a catch-all tax relief program.

In order to participate in this program, the applicable returns have to be amended and special forms 621/622 have to be filed by October 31, 2011. Also, the taxes and interest due on the amended returns must be paid by that same date. In some cases, the FTB will allow taxpayers to enter into an installment agreement, but only as long as the balances are paid in full by June 15, 2012. Finally, don’t think you’ll be able to walk away quietly. Under the terms of the program, the taxpayer or business agrees to cooperate in whatever investigation the FTB decides to conduct regarding the details of their illegal ATAT or OFA activities. The information collected from these inquiries will likely help FTB to track down future tax criminals.

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