Tag Archives: international tax evasion

The Internal Revenue Service (“IRS”) continues to make international tax evasion one of its top priorities. In general, all U.S. individuals, corporations and non-corporate entities are required to pay tax on their worldwide income and, under certain circumstances, file reports of foreign accounts. As the IRS continues to amass more information regarding foreign accounts, the risk to individuals, corporations and non-corporate entities who fail to report foreign accounts continues to increase. Because of the requests from taxpayers who want to disclose their foreign accounts but did not take advantage of the previous voluntary disclosure programs, and more importantly, due to the successes of the IRS’ 2009 Offshore Voluntary Disclosure Program (“2009 Program”) and the 2011 Offshore Voluntary Disclosure Initiative (“2011 Initiative”), the IRS has decided to open another Offshore Voluntary Disclosure Program (“New Program”). This New Program is similar to the 2011 Initiative (except for an increase in the highest penalty category) and will offer U.S. taxpayers a chance to resolve their tax liabilities under a fixed penalty structure and minimize their chances of criminal prosecution. Taxpayers who made voluntary disclosures after the closure of the 2011 Initiative are also eligible to participate in the New Program. The New Program is open for an indefinite period until otherwise announced. However, the terms of the New Program could change or it may be terminated at any time. Therefore, if you wish to participate in this New Program, you should act immediately. The IRS Commissioner has indicated that taxpayers who do not come forward voluntarily before the IRS finds them will face higher penalty scenarios, as well as the possibility of criminal prosecution.