Making Sense of the IRS Amnesty Program for Offshore Accounts
Thorn Law Group is a leader in providing tax counsel and legal representation to clients throughout the United States and around the world. Our firm is home to a team of highly effective, solution-oriented tax attorneys. Each Washington DC tax attorney at Thorn Law Group is focused on delivering superior tax planning advice and resolving complex tax disputes in the most effective and efficient manner.
The legal professionals at our firm are former IRS tax attorneys. This experience gives us a strategic advantage when navigating clients through the complex procedures and structures of government agencies and allows us to provide unique and invaluable insight into IRS policies and procedures. We have advocated in cases that involve business tax concerns and international tax issues, such as the reporting policies for offshore bank accounts and voluntary disclosures. We have provided legal counsel in many cases that include criminal tax investigations and general IRS audits and appeals.
The Internal Revenue Service is utilizing an increasingly large number of its enforcement employees to investigate U.S. taxpayers who have failed to disclose and/or report the income from their foreign bank accounts. As a result, if you have an account overseas, it is likely that you may be contacted by the Internal Revenue Service (IRS).
However, even if you have been contacted by the IRS, you still have options. There is a method by which taxpayers can voluntarily disclose their offshore account information: the IRS Offshore Voluntary Disclosure Program.
On January 9, 2012, the IRS introduced the reopening of its Offshore Voluntary Disclosure Program for Undisclosed Offshore Accounts, also known as the Amnesty Program. The basic terms of the program are as follows:
- Participants must pay back taxes and interest for up to eight years as well as accuracy related and/or delinquency penalties
- Participants must file all original and amended tax returns and include payments for taxes, interest and accuracy related penalties
- A 27.5% penalty on the taxpayers’ undisclosed offshore accounts with the highest aggregate account balance over an eight-year period
Though the Offshore Voluntary Disclosure Program can help taxpayers avoid serious IRS repercussions, it is complex and confusing. Just one small mistake and you can end up owing even more money to the government, or worse, face civil and criminal penalties. Fortunately, Managing Partner Kevin E. Thorn and the tax attorneys at Thorn Law Group are here to help.
Getting the IRS off Your Back – Once and for All
Thorn Law Group currently represents numerous individuals, trusts and companies, helping them to navigate the intricacies of the IRS Amnesty Program and the voluntary disclosure of their offshore accounts. A team of highly sought-after IRS attorneys, each member of Thorn Law Group is well-prepared to assist you in navigating your voluntary disclosure case.
Given the office’s proximity to the nation’s major tax law offices and courts, Thorn Law Group has experience representing clients in even the most challenging and detail-oriented courts. Thus, we are well-positioned to provide comprehensive and effective representation for our clients.
Major International Banks Subject to Investigation and What This Means for Taxpayers
If you have an account overseas, it is likely that your financial institution is under investigation. The majority of accounts impacted by the Voluntary Disclosure Program are in Switzerland, Canada, the Caribbean, Asia and Liechtenstein. Fortunately, Thorn Law Group has experience aiding clients with accounts from many major banks across the world. Regardless of where your assets are held, we can help you avoid government penalties. Below is a list of foreign banks currently under investigation:
- UBS
- HSBC
- WEGELIN
- CREDIT SUISSE
- JULIUS BAER
- DEUTSCHE BANK
- BANK HAPOALIM
- BANK LEUMI
- BASLER KANTONALBANK
- NEUE ZUERCHER BANK
- ZUERCHER KANTONALBANK
- LIECHTENSTEINISCHE LANDESBANK
- MIZRAHI-TEFAHOT BANK
Contact Our Tax Attorneys to Avoid Substantial Penalties for Your Offshore Accounts
When it comes to disclosing your offshore accounts, proactivity is key to achieving the positive results you deserve. The tax attorneys at Thorn Law Group are prepared to help you through the voluntary disclosure process, from start to finish, and with the utmost discretion. With years of experience in tax law, we understand what you are facing and can handle even the most unexpected of surprises that may arise in your case. We’ve helped hundreds of taxpayers save millions of dollars and avoid life-altering penalties, and are fully prepared to do the same for you.
If you can imagine a future free of legal tax burdens and are ready to get the IRS off your back for good, contact Managing Partner Kevin E. Thorn today at 202-349-4033 to schedule a confidential consultation.
