The attorney-client privilege is a solid legal protection that allows a client to discuss the details of foreign accounts and assets with an experienced tax attorney without concern of disclosure to the IRS. As your attorney, I will need comprehensive information about your foreign assets and investments, how they were reported, and the nature of those funds and assets in order to be able to effectively advise you. The attorney-client privilege protects all of your information so that you can make full disclosure of what has happened, so that we can strategize how and what to communicate to relevant tax authorities, and which programs or forms offer the best chance for a successful outcome in your case.
Recent developments involving Swiss bank and investment accounts, and other financial institutions around the world make it possible for the IRS to access specific account information and associate it with a unique tax payer ID. The IRS has begun to pour through that information, and this will impact not only the number of audits relating to foreign assets and income, but the acceptance or denial of those who have applied through OVDP or streamlined procedures to seek relief from FATCA and FBAR related penalties, even criminal exposure. If you have been contacted by the IRS, or the State of California on a tax matter relating to foreign accounts it is important to contact an experienced and proven tax attorney who can provide the protections of attorney-client privilege.