In February of this year, the US Government Accounting Offices (GAO) released a report that showed a staggering $2 Trillion dollars in hidden Swiss bank and investment accounts, and that 24% of those holding affected Swiss accounts were residents of California. California residents who have previously shielded income and assets in Swiss accounts face criminal tax charges, as well as extremely high tax burdens, penalties and interest. This is a complicated issue requiring a variety of professional expertise across the legal, tax and accounting spectrum of services.
Allen Barron is uniquely positioned to provide a single source of expertise for Californians who face the wrath of the IRS due to their Swiss accounts. The first, and most substantial consideration is the protection of attorney-client privilege. This legal protection does not extend to relationships with tax advisors and CPAs. The challenge for these clients is the nature of the information they need to divulge in order to genuinely evaluate their options and ultimately determine a course of action. Janathan Allen is an attorney, as well as a tax expert and Certified Public Accountant. You can take advantage of attorney-client privilege to discuss the nature of your offshore accounts and assets, the potential liabilities you face and seek counsel without exposing this information to the risk of being subpoenaed by the IRS during an audit or criminal tax process.
If you have accounts or assets that you have overlooked in your Foreign Bank Account Report (FBAR) for the past several years, or substantial assets that you have previously shielded in Swiss accounts the time to take action is now. June 30 is a critical date for FBAR reporting, and this is the first step in the process. We will also discuss the Offshore Voluntary Disclosure Program, and the opportunities for you to avoid criminal exposure while minimizing the financial impact of recent developments.
Events are unfolding at a rapid rate. It is important to seek expert and experienced guidance to minimize your exposure and work through to a solution that allows you to focus on continuing to build your portfolio for the future.
