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....

History of the Internal Revenue Service’s Voluntary Disclosure Program

This is a two-part blog post on the evolution of IRS voluntary disclosure programs.  The first post traces these programs from their inception through the 1990's.  The second post discusses the programs beginning in 2000 and carrying through to the present day. Overview Since the Justice Department sued UBS in...

White Collar Crime, Structuring

Federal law requires business and financial institutions to report currency transactions in excess of $10,000 in a single or “related” transaction within a twelve-month period. Businesses must file an IRS form 8300 and financial institutions must file a currency transaction report. Even though making a deposit or withdrawal greater than...