Taxpayers Face Offshore Account Disclosure Dilemma

Law360, New York (April 10, 2017, 12:31 PM EDT) -- Kaitlyn Gardner

Christopher Karachale Nearly eight years ago, the U.S. Internal Revenue Service introduced the voluntary disclosure program for taxpayers with undisclosed accounts and assets. Taxpayers who remain delinquent in reporting their foreign assets and accounts should be anxious. These individuals are subject to ever-increasing scrutiny from the IRS as it seeks to enforce reporting requirements and penalize people who fail to meet their obligations.

What is a worried taxpayer to do? The IRS has considered that some individuals may actually want to come into tax compliance in the United States but are afraid to do so. Accordingly, the IRS offers...

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