The US Department of Justice (DOJ) and the IRS have worked for the past several years to establish the perfect crossfire scenario: foreign banks and US citizens forced to provide information on each other to the IRS. The US threatens sovereign nations and foreign banks with sanctions and the inability to participate in US markets, as well as criminal prosecution resulting in millions if not billions of dollars in settlements.
The nations and their banks and tax agencies (almost 100 so far) have capitulated to FATCA and are providing detailed information about US taxpayers, their accounts and their monetary activity over several years to the IRS. The IRS then requires US taxpayers to conform and comply with FBAR regulations providing specific account information the IRS and DOJ can cross reference to pursue the foreign banks.
In both cases the end result is this: heavy fines and revenue for the US Treasury.
Acting Assistant Attorney General Caroline D. Ciraolo of the Department of Justice’s Tax Division said it quite clearly: “The days of safely hiding behind shell corporations and numbered bank accounts are over.”
The message to you as a US taxpayer with foreign accounts and assets is clear: it is time to come into compliance with the IRS, and to face the realities of the Swiss capitulation and transparency. You must protect yourself, and take advantage of the attorney-client privilege to ensure that the IRS cannot further compel information from your CPA or tax advisor that will be used against you to increase your exposure and tax liabilities.
Call us for a free and substantive consultation at 866-631-3470. We will work with you to develop a strategy to minimize the damage, limit present and future exposure and prevent the genuine risk of criminal tax liability.
