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News & Events

Archive by Year:2009 - Page 10

IRS Offers Settlement Initiative for US Taxpayers with Undeclared Offshore Accounts

Articles & Publications

Posted in on March 26, 2009

On March 26, 2009 the IRS provided guidance to its field agents on how to deal with U.S. taxpayers who own interests in foreign (offshore) financial accounts that they have previously not disclosed to the IRS.  Failure to disclose such accounts to the IRS is punishable by a heavy fine and, in some cases; criminal charges may be brought against the taxpayer.  However, IRS Commissioner Douglas Schulman announced if these taxpayers come forward and divulge all of the information regarding their offshore accounts they can expect significant penalty relief. The penalty relief portion of the voluntary disclosure program will only be available to taxpayers who come forward within the next six months, or by September 26, 2009.

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Changes to the contingency section of Circular 230

IRS Office of Professional Responsibility

Posted in on March 18, 2009

The IRS and the IRS Office of Professional Responsibility will be looking at changing the contingency section of Circular 230.

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Meeting at the IRS Discussing Regulation of Return Preparers

IRS Office of Professional Responsibility

Posted in on February 4, 2009

There was a meeting at the IRS this past week to discuss the regulation of return preparers.

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UBS Bank Closing All U.S.-held Offshore Accounts May Cause New Hazards for Taxpayers

Articles & Publications

Posted in on January 15, 2009

Last week, Swiss banking giant UBS AG (UBS) reported that it will close all secret offshore accounts held by U.S. accountholders amid growing pressure from U.S. tax authorities investigating potential tax avoidance by U.S. taxpayers.  The move aids federal authorities in investigating accountholders for filing false tax returns, willful failure to disclose accounts, tax evasion and tax fraud by exposing evidence of the undisclosed accounts.  As discussed earlier this month in the Williams Mullen Tax Law Team Alert, U.S. Government Targets UBS Offshore Account Holders, federal authorities estimate that 19,000 U.S.-held UBS accounts have been used to hide $18 billion in assets - or $300 million in tax liabilities - each year. 

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ABA Tax Section Meeting, Sanction Guidelines and IRS’s OPR


Posted in on January 9, 2009

Kevin E. Thorn was a panelist at the ABA Tax Section, Standards of Tax Practice meeting in New Orleans.  Mr. Thorn discussed the Sanction Guidelines and other issues involving the IRS’s Office of Professional Responsibility with Acting Director, Carolyn Gray.

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