IRS Accelerates Attack on Foreign Offshore Bank Accounts

Hardly a day passes when we do not hear of yet another country entering agreements with the IRS that have the effect of requiring financial institutions in those countries to make various disclosures to the IRS regarding U.S. taxpayers’  offshore bank accounts. Recently there have been announcements regarding Barclay’s private bank in Switzerland.  Last week,…

Quiet Disclosures Are Making A Lot of Noise

Since the onset of the original Offshore Voluntary Disclosure Initiative (OVDI) in 2009 and its successor Offshore Voluntary Disclosure Program (OVDP) and subsequent progeny programs, taxpayers with undisclosed offshore accounts or foreign accounts have for the most part been able to avoid criminal prosecution at the expense of paying fines for failing to disclose and…