IRS Offshore Voluntary Disclosure Initiative (OVDI)

If you searched for IRS OVDI, you are aware that the Department of Justice and the Internal Revenue Service have instituted massive campaigns in the last couple of years to find and collect tax on worldwide income, investment, and assets. As a result of these campaigns, the DOJ and IRS designed the 2011 Offshore Voluntary Disclosure Initiative. The State of California has recently developed its own program.

The federal program offers benefits to encourage taxpayers to disclose foreign accounts now, including but not limited to ownership interests in foreign entities such as corporations, partnerships, trusts, wire transfers, annuities or life insurance plans, etc.  By participating, individuals may avoid the risk of IRS detection and criminal prosecution and mitigate severe monetary penalties. The deadline for participation in this program is August 31, 2011.

This 2011 OVDI may provide an excellent opportunity for individuals to come into tax compliance and void serious punishments.   However, participation in the program may also result in an investigation and/or audit by the criminal investigation division of the IRS, in which full and complete disclosure and cooperation are essential in order to utilize this OVDI and not invite other possible criminal and civil actions. Note that participation in OVDI does not offer amnesty for other crimes uncovered in the investigation. Further absent full and complete disclosure and cooperation, the government may find cause for failure to supply information, or false statements. Finally, while non-participation in the program may be a calculated avenue for some, it potentially leaves individuals vulnerable to criminal prosecution for counts including but not limited to, FBAR violation, conspiracy, perjury, tax evasion, failure to supply information, etc.

We are currently representing many individuals in light of the offshore disclosure initiatives and we invite you to contact us.

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