Immigration Criminal Tax Consequences of Failing to Disclose Foreign Bank Accounts and Foreign Source Income

with thanks to Liz Prehn, Law Clerk Introduction The recent crackdown by the Internal Revenue Service (IRS) on United Sates taxpayers with previously undisclosed foreign bank accounts and unreported foreign income has resulted in an unprecedented wave of criminal prosecutions. The IRS' initiative may also result in criminal convictions and...

2011 Voluntary Disclosure Initiative (OVDI) for Unreported Offshore Accounts

There has recently been a flurry of press surrounding the IRS' announcement of a new 2011 Voluntary Disclosure Initiative (OVDI) for offshore accounts. This program is part of the Department of Justice's targeting of offshore bank account holders who fail to report income associated with the account on their U.S....