Skip to content
Tax Law Center Blog

Tax Law Center Blog

  • Tax & Foreign Assets
    • Tax Law Services
    • Foreign Asset Planning
  • About
  • Contact Us
Close Button

The IRS Large Business and International division (LB&I) has announced a new Offshore Private Banking enforcement campaign

12 July, 2019

The new Offshore Private Banking enforcement campaign was recently identified through LB&I data analysis and suggestions from IRS employees. IRS employees likely saw that many taxpayers were not properly reporting offshore bank accounts, as a result, they suggested the campaign. The IRS Offshore Private Banking enforcement campaign goal is to improve return selection, identify issues representing a risk of non-compliance, and make the greatest use of IRS limited resources.

U.S. persons are subject to tax on worldwide income from all sources including income generated outside of the United States. It is not illegal or improper for U.S. taxpayers to own offshore structures, accounts, or assets. However, taxpayers must comply with income tax and information reporting requirements associated with these foreign activities, otherwise, they are subject to penalties and possible criminal prosecution.

Via FATCA and subpoenaed bank records, the IRS is in possession of records that identify taxpayers with transactions or accounts at offshore private banks. This campaign addresses tax noncompliance and the information reporting associated with these offshore accounts. The IRS will initially address tax noncompliance through audit examination and soft letter treatment streams. Soft letters are IRS correspondence to targeted taxpayers identifying tax noncompliance and passively seeking compliance.  Failure to respond to such letters may result in audit or penalties and possible criminal prosecution.

In the meantime, Patel Law Offices has consulted with hundreds of clients regarding their offshore asset and income compliance issues. Patel Law Offices is a law firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems. Our firm assists (and defends) clients and their advisors to legally disclose (and legitimize) foreign assets.

 

Related Posts

  • IRS Announces Increased Enforcement on Form 5471

    On April 16, 2019, the Large Business and International (LB&I) Division of the Internal Revenue…

  • IRS Announces new OVDP Declines-Withdrawals Campaign

    Earlier this month, the IRS' Large Business and International division released its list of 13…

  • The IRS is Hiring: Expect New Enforcement

    I recently returned from the American Bar Association’s Taxation conference in Washington, D.C., which is…

Tags: foreign accountoffshore offshore accounts OVDP
Category: Planning for Tax Minimization

Post navigation

Previous: Details of the Streamlined Domestic Offshore Procedures
Next: Details of the Streamlined Foreign Offshore Procedures (SFOP)

Related Posts

NJ Men Indicted for Conspiring to Defraud IRS Through Cash Wage Scheme

In a case that highlights the serious consequences of payroll…

Read More

FATCA-Compliant Institutions List Goes Online

While over 77,000 banks and financial institutions have registered under…

Read More

Details of the Delinquent International Information Return Submission Procedures (DIIRSP)

The Delinquent International Information Return Submission Procedures are one of…

Read More

Recent Posts

  • The High Price of Payroll Tax Non-Compliance: Lessons from United States v. PittsSeptember 15, 2026
  • FBAR Willfulness, Recklessness, and the Excessive Fines Defense: Key Takeaways from United States v. RundSeptember 11, 2026
  • FBAR Enforcement and Penalty Analysis: United States v. NiksichSeptember 5, 2026
  • Billions Offshore, Millions Missed: What TIGTA’s Report Means for FATCA EnforcementSeptember 2, 2026
  • Criminal Tax Enforcement Takes Center Stage: The National Fraud Enforcement Division MemorandumAugust 21, 2026
  • Navigating New Jersey Tobacco and Vapor Excise Tax AuditsAugust 11, 2026
  • Navigating the US Estate Portability Election: Strategic Timing and Compliance Procedures for Form 706July 13, 2026
  • IRS Transitions from First Time Abatement to Automated Penalty Relief: Strategic Impacts for Tax AdvisorsJuly 11, 2026
  • Parag Patel to Present on IRS Foreign Asset Enforcement at the 2026 NATP TaxposiumJuly 9, 2026
  • The End of the IRS Delinquent FBAR Submission Procedures?: Still Available under IRM 4.26.16.3.11July 8, 2026

Law Firm Attorney WordPress Theme By Themespride