• The IRS’s Current Offshore Voluntary Disclosure Program: Is This the Only Option Available for An “Accidental American”??
  • January 30, 2014 | Authors: Pedro E. Corona de la Fuente; Eric D. Swenson; Raul Villarreal Garza
  • Law Firm: Procopio, Cory, Hargreaves & Savitch LLP - San Diego Office
  • Since primarily 2008, the Department of Justice (“DOJ”) and the Internal Revenue Service (the “IRS”) through their well publicized international tax enforcement initiative, have targeted, among others, U.S. individual taxpayers who have: (i) knowingly failed to disclose offshore financial accounts (e.g., indicated “no” foreign financial accounts on tax returns and did not file Report of Foreign Bank and Financial Accounts (“FBAR”)); and (ii) knowingly failed to report and pay U.S. income tax on income earned from such foreign financial accounts (the “Tax Cheats”).