Liechtensteinische Landesbank

The IRS and US Department of Justice (DOJ) investigation of US taxpayers with undisclosed offshore accounts is not limited to accounts at Swiss banks.  IRS and DOJ officials have announced that they are actively investigating the bank Liechtensteinische Landesbank for allegedly helping US taxpayers commit tax fraud through use of undisclosed offshore accounts in Liechtenstein.

The IRS is asking Liechtensteinische Landesbank, to turn the names of US taxpayers with accounts in Liechtenstein.   US taxpayers with offshore accounts, trusts, foundations or other property in Liechtenstein should take steps as soon as possible to ensure that their foreign accounts and assets are properly reported to the IRS and are encouraged to disclose their offshore accounts to the IRS through the offshore voluntary disclosure program.

The Thorn Law Group represents U.S. taxpayers making voluntary disclosures of their offshore accounts as well as tax payers who did not make a voluntary disclosure but are being investigated by the IRS and the Department of Justice for failure to disclose their offshore accounts.

On January 9, 2012, the IRS announced its 2012 Offshore Voluntary Disclosure Program for taxpayers with undisclosed offshore accounts.

The basic terms of the program are:

  1. A 27.5 percent penalty of the undisclosed offshore accounts based on the highest aggregate account balance over the past eight-year period.
  2. Participants must pay back taxes and interest on any unreported income and interest for up to eight years as well as accuracy related and/or delinquency penalties.
  3. Participants must file all original and amended tax returns and include payments for taxes, interest and accuracy related penalties.

Taxpayers who successfully complete the Offshore Voluntary Disclosure Program will likely avoid criminal prosecution or  jail time.  They will also not be liable for taxes or penalties prior to the years disclosed in the program.

The IRS has not stated how long the 2012 Offshore Voluntary Disclosure Program will be available, and could close it at any time.

To take advantage of this opportunity and to potentially avoid substantial civil and criminal penalties, contact Kevin E. Thorn, Managing partner at Thorn Law Group today at or call 201-355-8202.

This is an area of ongoing activity by the IRS and the Department of Justice. Check out our News & Events page for the latest developments regarding undisclosed offshore accounts.


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