Under federal law, U.S. taxpayers have an obligation to report their offshore assets and income to the IRS. Failure to report offshore assets and income can lead to substantial penalties—and possibly even to criminal prosecution of the Internal Revenue Service (IRS) determines that you have willfully withheld information about your foreign holdings or revenue sources in order to evade federal income tax liability. The IRS’ Voluntary Disclosure Practice provides taxpayers with the opportunity to mitigate the consequences of untimely disclosure, but making mistakes when attempting to take advantage of the program can lead to undesirable consequences as well.Read More

The Internal Revenue Service Criminal Investigations division (IRS CI) investigates tax crimes and collects evidence that the U.S. Department of Justice (DOJ) can use to pursue criminal charges in federal district court. As a result, facing an IRS CI investigation is a serious matter; and, if you have been contacted by special agents from IRS CI, it is important that you speak with a Washington D.C. criminal tax lawyer promptly.Read More

For U.S. taxpayers who are concerned about their filing or payment history, the Internal Revenue Service’s (IRS) Voluntary Disclosure Practice provides a potential way to resolve past deficiencies without facing criminal liability. However, utilizing the Voluntary Disclosure Practice can be extremely risky if not handled carefully; and, as a result, individuals who are thinking about self-disclosing federal tax law violations should consult with a Washington DC IRS voluntary disclosure lawyer before they submit anything to the IRS.Read More

In January, we discussed the IRS’s announcement of the first major crackdown executed by the Joint Chiefs of Global Tax Enforcement (J5), a collaborative international law enforcement effort focused on combating the illegal use of offshore banks and shelter schemes for tax evasion. In February, the IRS released an update on the J5’s enforcement efforts in a News Release captioned, “J5 tax chiefs closing the net on global tax evasion.”Read More

For years, individuals who inadvertently failed to report offshore assets to the federal government were able to do so under the IRS’s Offshore Voluntary Disclosure Program (OVDP). However, the IRS closed the OVDP in 2018. In 2019 and beyond, the primary option available to federal taxpayers is the IRS’s Streamlined Disclosure Program for Offshore Accounts.Read More