Many accounting firms are not using or are improperly utilizing Kovel letters to protect their client’s interests in offshore voluntary disclosures.

Now that the settlement initiative has ended, what will the IRS do next to find individuals with offshore accounts?

Thanks to UBS, we now have a blueprint of how the IRS and DOJ will shape their tax evasion investigations vis-a vis offshore accounts.

The IRS Offshore Account Voluntary Disclosure Program (the “Program”) is over.  But that does not mean U.S. taxpayers with undisclosed foreign bank accounts should stay in hiding.  In fact, the relative success of the Program makes it imperative for people with still undisclosed accounts to come forward and make a voluntary disclosure.

Now we know how UBS will determine which U.S. clients to turn over to the IRS.