Foreign Bank Account Representation – Offshore Practice
Identifying U.S. taxpayers and entities that use secret offshore bank accounts remains a top priority for the Department of Justice.
For years, numerous taxpayers holding offshore or foreign bank accounts or having offshore income have not disclosed the existence of these accounts or claimed income from them on their income tax returns. These taxpayers thought that the U.S. government could not obtain information about their accounts.
THINGS HAVE CHANGED
Through its Offshore Compliance Initiative, Foreign Account Transaction Compliance Act (FATCA), and the use of Conventions and Tax Treaties, the US will easily identify individuals and entities with offshore bank accounts and other financial interests overseas.
The US has been very active in criminally prosecuting identified individuals, as well as assessing tremendous penalties and fines.
Criminal FBAR Related:
Civil: Offshore Practice Group
The offshore voluntary disclosure programs administered by the IRS have resulted in over thirty thousand US taxpayers coming forward and in exchange for lower penalties and no criminal prosecution. These programs have revealed banks, bankers, lawyers and associated parties who are then prosecuted to the full extent of the law.
Voluntary Disclosure for Offshore Bank Accounts, Failure to report FBAR
Civil Tax & FBAR Penalties