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IRS Signals Intent to Aggressively Pursue Undisclosed Offshore Accounts

At the recent National Institute on Criminal Tax Fraud and Tax Controversy, senior IRS and Department of Justice (Tax) officials sounded the proverbial warning alarm to taxpayers with undisclosed or offshore financial accounts. The message was clear: “We are getting information daily, and we will find you if we have not already.”

Voluntary Disclosure Results Reported

Officials report that the voluntary disclosure programs have generated over 100,000 combined submissions and over $10 billion dollars in tax, penalties and interest. The government believes that there are billions more to be collected.

Warning to Taxpayers: The Government Is Using Aggressive Data Collection Techniques To Find You

To date, over 175 "John Doe" summonses to financial institutions have resulted in millions of pieces of data. Spontaneous exchanges from international financial institutions are now commonplace. In other words, clients of foreign financial institutions may not even be aware that their information has been shared with the U.S. government. The United States plans to issue more John Doe summonses regarding crypto currencies seeking account holder information. They will match the data to tax filings and information and look for inconsistencies. Criminal and/or civil examinations will follow.

Minimizing Exposure

Time is of the essence to minimize exposure both financially and criminally. Contact us to evaluate your particular situation and to determine if a voluntary disclosure is appropriate for your circumstances.

© 2020 Varnum LLP


About this Author

Eric M. Nemeth, Tax Planning Attorney, Varnum, Financial Controversy Lawyer

Eric is a partner and leads the tax team. He concentrates on tax and financial controversy (IRS and various States) from examinations appellate conferences, criminal investigations, witness representation and civil and criminal tax litigation. He works with government regulatory and general tax matters. He has served as Senior Trial Attorney for the District Counsel of the Internal Revenue Service and as Special Assistant U.S. Attorney for the Department of Justice. He is a frequent speaker on tax enforcement and has served as an expert witness and binding arbitrator....

Wayne D. Roberts, Corporate tax attorney, Varnum

Wayne is a member of Varnum’s Tax Team. His practice includes all aspects of federal and state tax planning and tax litigation. He represents both closely-held and Fortune 100 companies in tax disputes with the IRS, the Michigan Department of Treasury, and revenue departments in Pennsylvania, Indiana, Tennessee, New York, California and numerous other state and local taxing jurisdictions.