Voluntary Disclosures and Non-Filer Program
We routinely provide advice for U.S. taxpayers with unfiled tax returns and offshore bank accounts with respect to their exposure to criminal tax liability in navigating the Voluntary Disclosure rules and the Non-Filer Program. With the recent amendments to the whistleblower provisions, the Internal Revenue Service has far more access to information relating to offshore bank accounts and investments. This is evident from the UBS investigation, which has led to more than 17,000 voluntary disclosures since 2009. Following the successful UBS prosecution, the Internal Revenue Service has extended its focus to a number of other offshore banks and financial institutions. Although we have on occasion represented clients before the Internal Revenue Service Criminal Investigation Division and the Department of Justice, we do not serve as trial counsel in criminal tax matters.