The IRS Offshore Audits Have Begun
The IRS has begun the first round of offshore income, asset and bank account reporting audits, and once contacted by the IRS a taxpayer cannot file OVDP or other FBAR compliance paperwork or applications. At this point the only alternative is to contact the experienced IRS tax attorneys at Allen Barron and prepare for a challenging IRS examination. Your best hope is that the IRS does not elect to pursue criminal charges seeking your internment in a federal prison. Our work with the IRS will make a substantial impact in the outcome of all of these issues.
For those who have not yet been contacted by the IRS, there is genuine hope. However, any US taxpayer (resident or foreign) who has not come into FBAR reporting compliance with the IRS through either the Offshore Voluntary Disclosure Program or OVDP, or the streamlined domestic (foreign) offshore procedures should take IMMEDIATE ACTION to apply through one of the programs. Once the IRS contacts you, your options cease – the only path forward is a full audit, maximum penalties of 50% of the highest accumulated offshore account balance for each year in question, and for each account, or $100,000 per incident whichever is higher. It doesn’t matter how much is in your accounts today. Without the OVDP or other compliance in many cases the amount of the penalties and interest will far exceed present account balances and asset values.
The domestic and international tax attorneys at Allen Barron, led by Janathan Allen, are prepared to guide you through the process and help you to evaluate risks and the best alternative available based upon your unique circumstances. If you have not fully disclosed all offshore investment and bank accounts and assets to the IRS for the past six to eight years the time is upon you to consider OVDP or other FBAR compliance in the immediate future. We invite you to contact us for a free and substantive consultation at 866-631-3470. Learn about the attorney-client privilege and the inter-disciplinary services available to you through Allen Barron such as accounting, tax preparation and CPA services.