Tax Law Center Blog

Even though the deadline for the Internal Revenue Service’s 2011 Offshore Voluntary Disclosure Initiative has concluded last week, U.S. taxpayers with undisclosed offshore accounts still have the opportunity to come forward through the IRS’s traditional Voluntary Disclosure program. Like the OVDI, the traditional Voluntary Disclosure program provides taxpayers an opportunity to come forward and potentially avoid criminal prosecution. The IRS has detailed the terms of its existing traditional Voluntary Disclosure Practice in its Internal Revenue Manual (IRM) 9.5.11.9 (titled “TAX CRIMES – GENERAL”).

For individuals who fail to disclose foreign assets and income, both the IRS and Department of Justice have repeatedly stated that taxpayers with undisclosed offshore bank accounts will be pursued by the government, potentially becoming subjects of criminal investigations.

Parag Patel of Patel Law Offices believes that recent developments with investigations into prominent private offshore wealth management banks, regional – or cantonal – Swiss banks, as well as such large banks as Credit Suisse and HSBC, have heighten the risks of not disclosing a foreign account. Taxpayers who have not disclosed their offshore bank accounts should do so before the Department of Justice begins to open investigations against them; information provided by Credit Suisse, HSBC or other banks during these investigations may be used by the IRS and the Department of Justice to support new investigations into U.S. taxpayers suspected of evading taxes.

Parag Patel of Patel Law Offices, a law firm that represents many taxpayers throughout the U.S. and around the world with undisclosed offshore accounts states, “For taxpayers with undisclosed accounts who were unable to take advantage of the recent 2011 (and 2009) IRS Amnesty Program, now is the time for you to come forward and learn about other options the IRS provides in regards to voluntary disclosure in order to limit potential civil penalties and criminal exposure”.

Mr. Patel encourages all taxpayers with undisclosed offshore bank accounts to “contact a tax attorney immediately in order to learn of other disclosure options and to assess their exposure.”

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 accounts.