Global “Tax” Resolution: U.S. Government Engages in Resolution to Prevent Undisclosed Offshore Accounts

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U.S. government agencies and European banks are currently working on an agreement, known as the Global Resolution, to put an end to U.S. tax evasion. Thorn believes the agreement will lead the way to the release of further U.S. taxpayers’ names to the U.S. government, which will continue the on-going criminal investigations.

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I believe this is the perfect time for taxpayers with undisclosed accounts to take advantage of the IRS’s New Amnesty Program for undisclosed offshore account holders before the foreign banks turn over clients’ names to the IRS or DOJ.

Similar in concept to the Deferred Prosecution Agreement (DPA) signed by UBS, the U.S. is currently involved in talks with several European banks, which may result in an agreement known as the Global Resolution. Government authorities speculating think terms of the agreement involve a respective bank to pay a fine to the U.S. government, and to provide U.S. clients’ names in exchange for the U.S. government discontinuing any pending investigation against said bank. Fines to be paid to the U.S. government as a result of the agreement may possibly generate billions of dollars. An announcement of the final settlement terms, as well as specific banks participating in the agreement, could come as early as July, 2011.

Kevin E. Thorn, Managing Partner of Thorn Law Group, a law firm that represents taxpayers throughout the U.S. and around the world, with undisclosed offshore accounts, believes that, “Any bank approached by the U.S. government to enter into the agreement would, in all likelihood, accept in order to continue good diplomatic relations with the U.S. government and not face possible lawsuits brought on by the U.S.”

Over the past several years, the United States Internal Revenue Service (IRS) and Department of Justice (DOJ) have been gathering information for cases against several foreign banks that have been suspected of assisting U.S. taxpayers in hiding their assets in undisclosed offshore accounts. Implementing the two voluntary disclosure programs (2009 Voluntary Disclosure Program and 2011 Offshore Voluntary Disclosure Initiative) provided the opportunity for taxpayers to come into compliance with amnesty from criminal prosecution. The IRS and DOJ have been successful in collecting evidence against several European banks that provided the means for tax evasion.

Mr. Thorn states, “When UBS signed the DPA, proposed by the U.S. Government, a profusion of offshore account holders came forward in order to come into compliance with the IRS. This was a turning point for the IRS in its effort to bring U.S. taxpayers into compliance.” Mr. Thorn continues, “This has changed the traditional notions of Swiss banking secrecy and will ultimately give the U.S. a firmer position in terms of relations with other banks that are believed to be aiding U.S. persons in tax evasion.”

Mr. Thorn further commented, “I believe this is the perfect time for taxpayers with undisclosed accounts to take advantage of the IRS’s New Amnesty Program for undisclosed offshore account holders before the foreign banks turn over clients’ names to the IRS or DOJ. There is no guarantee that a third voluntary disclosure of offshore accounts will be offered by the IRS.”

Undisclosed account holders should come forward before the government brings either civil audits or criminal charges against them; which can result in significantly greater financial penalties and the possibility of incarceration. Immediate action and experienced tax law representation is needed to voluntarily disclose your account in order to avoid criminal prosecution.

For additional information on the news that is the subject of this release, contact Kevin E. Thorn, Managing Partner of Thorn Law Group at 202-270-7273 or visit us at http://www.newjersey-tax-lawyer.com.

About Thorn Law Group, PLLC:
Thorn Law Group, PLLC is a law firm dedicated to helping clients resolve complicated international tax and financial problems.

Contact:
Kevin E. Thorn, Managing Partner
Thorn Law Group, PLLC
202-349-4033
http://www.newjersey-tax-lawyer.com

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