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Tag: voluntary disclosure

> Blog > voluntary disclosure

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.

www.mwattorneys.com

California Declares Amnesty Program a Success

Posted by Wetenkamp on November 18, 2011 with 0 Comment

The federal government and many of the states have offered limited tax relief and the promise of escaping criminal prosecution to those who voluntarily come forward and confess the tax sins of their past. California’s second voluntary compliance initiative (aka, VCI 2) was expected to bring in $270 million, and preliminary numbers suggest that it has done much better than that.

VCI 2 gave taxpayers who stashed money offshore or who engaged in abusive tax avoidance transactions an opportunity to amend their tax returns without penalties. The California tax relief program raised $350 million from over 1000 taxpayers.

The Franchise Tax Board’s warning to those who did not participate:

Taxpayers who were eligible for VCI 2 because of their involvement with abusive tax avoidance transactions but did not to participate are subject to audit for 12 years with large penalties such as the 40 percent Noneconomic Substance Transaction penalty and a 50 or 100 percent interest-based penalty.

www.mwattorneys.com

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.

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