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The IRS and the US Department of Justice (DOJ) are actively investigating the Swiss bank Wegelin following the recent indictments of Wegelin bankers on charges they helped US taxpayers in committing tax fraud through use of undisclosed offshore accounts at the Swiss bank.

US taxpayers with offshore accounts or other property should ensure that their foreign accounts and assets are properly reported to the IRS or face steep financial penalties and criminal charges.  The US and Swiss tax authorities are currently negotiating an information exchange and the window is closing for US taxpayers who have not disclosed their accounts to the IRS to come into compliance before the Swiss identify them to the IRS.  Taxpayers are encouraged to disclose their offshore accounts to the IRS through the IRS offshore voluntary disclosure program.

The Thorn Law Group represents U.S. taxpayers making voluntary disclosures of their offshore accounts as well as taxpayers 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 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 ket@thornlawgroup.com 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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