IRS’s New Amnesty Program for Undisclosed Offshore Account Holders Comes at a Critical Time: Swiss Banks Turn Over U.S. Client Data, Thorn Comments

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IRS launches a third amnesty initiative, the 2012 Offshore Voluntary Disclosure Program. Kevin E. Thorn encourages U.S. taxpayers with undisclosed offshore accounts to come into compliance in light of new developments between U.S. authorities and Swiss banks.

With the renewal of a third Voluntary Disclosure Program it seems clear that the IRS is dedicated to providing taxpayers with opportunities to come forward.

On January 9, 2012 the Internal Revenue Service (IRS) reopened its Offshore Voluntary Disclosure Program (OVDP) to encourage U.S. taxpayers with undisclosed offshore accounts to come into compliance. The 2012 Amnesty Program was in response to continuing interest from U.S. taxpayers after the 2009 and 2011 programs ended, making this program the third in the past three years.

In recent news, the IRS reported that eight Swiss banks, including Credit Suisse, Julius Baer, and Basler Kantonalbank turned over U.S. client data on taxpayers suspected of tax evasion on January 30, 2012. This does not put an end to the negotiations between the U.S. and Switzerland; three more banks are still expected to turn over client data and a total of 11 banks are excepted to pay heavy fines. Among the 11 banks include: Credit Suisse, HSBC Holdings Plc, Basler Kantonalbank, Wegelin & Co., Zuercher Kantonalbank, Julius Baer Group Ltd., Bank Leumi Le-Israel BM, Bank Hapoalim BM, Mizrahi-Tefahot Bank Ltd., Liechtensteinische Landesbank AG, and NZB AG.

Kevin E. Thorn, Managing Partner of Thorn Law Group, a law firm that represents many taxpayers throughout the U.S. and around the world with undisclosed offshore accounts in the 2009, 2011 and now 2012 IRS Amnesty Program states, “With the renewal of a third Voluntary Disclosure Program it seems clear that the IRS is dedicated to providing taxpayers with opportunities to come forward, which is something that taxpayers with undisclosed offshore accounts should strongly consider in light of this new development.” Mr. Thorn continues, “The risk of criminal and/or substantial civil penalties grows greater as the Internal Revenue Service and Department Of Justice complete more bank-investigations and as, foreign banks continue to cooperate with U.S. government officials.”

Mr. Thorn emphasizes that the risk of the IRS discovering a taxpayer’s undisclosed offshore accounts with this new development has increased ten-fold. The consequences for failure to comply with the proper disclosure requirements and filing requirements may lead to audits, severe financial penalties, and in some cases, criminal prosecution. The U.S. government is committed to bringing all U.S. taxpayers with undisclosed offshore accounts into compliance.

Mr. Thorn encourages all U.S. taxpayers to, “consult with a tax controversy attorney immediately in order to assess and minimize their civil and criminal exposure throughout these ongoing investigations and to take advantage of the new 2012 Offshore Voluntary Disclosure Program.”

For additional information on the news that is the subject of this release, contact Kevin E. Thorn, Managing Partner of Thorn Law Group at 617-692-2989 or visit us at http://www.boston-tax-lawyer.com/.

About Thorn Law Group, PLLC: Thorn Law Group, PLLC is a law firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems.
Contact:
Kevin E. Thorn
Managing Partner Thorn Law Group, PLLC
617-692-2989
http://www.boston-tax-lawyer.com/
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