Federal Government Pushes For Prison Time On U.S. Taxpayers With Undisclosed Offshore Accounts

Posted in Press Releases on September 30, 2014 | Share

Kevin E.Thorn, Managing Partner of the Thorn Law Group discusses the recent effort by the Internal Revenue Service and the U.S. Department of Justice to penalize and imprison U.S. taxpayers with undisclosed offshore accounts.

Washington, DC (PRWEB) September 30, 2014 - Earlier this year, a U.S. district court sentenced Ty Warner, the creator Beanie Babies, to two years’ probation for tax evasion.  Mr. Warner had earlier pled guilty to criminal charges for not declaring offshore Swiss accounts and paid $53 million to the U.S. government as part of his settlement, along with $27 million in back taxes. 

The Department of Justice (DOJ) is now appealing the sentence of probation without jail time.
[U.S. v. Warner, U.S. Court of Appeals for the Seventh Circuit, Docket No. 14-1330.]

Kevin E. Thorn, Managing Partner of Thorn Law Group, explains, “It can be argued that the federal government is out to make an example of Ty Warner by appealing his sentencing and re-questing prison time.” Thorn anticipates the DOJ is “signaling to all U.S. taxpayers that the U.S. government takes failure to disclose offshore accounts seriously and will continue to seek jail time for those who have been hiding assets and accounts overseas.”  Thorn also notes, “The federal government has many ways of finding out information about U.S. taxpayers with undisclosed overseas accounts, - one of the new ways is through the Foreign Account Tax Compliance Act, “FATCA”.  Under FACTA, foreign banks and financial asset managers - including brokers and trustees - are required by law to disclose the accounts that belong to Americans who have undisclosed overseas accounts valued at more than $50,000. [See,]

Kevin E. Thorn, states, “United States Taxpayers with undisclosed offshore accounts should come forward and get back into compliance immediately by entering into the IRS's Offshore Voluntary Disclosure Program.”  He points out, “The penalty for not disclosing offshore accounts can be devastating; “adding”, U.S. Taxpayers with undisclosed foreign bank accounts should also be aware that once the DOJ and the IRS obtain the identities of those U.S. Taxpayers with hidden foreign accounts in overseas banks, the federal government will not allow those account holders to enter into the IRS's Offshore Voluntary Disclosure program, the IRS and DOJ may prosecute them instead, or seek maximum civil penalties.

Mr. Thorn also notes, "The risk of financial penalties for a U.S. taxpayer with undisclosed off-shore accounts is becoming a certainty, and now the federal government also wants to push for prison time for violators of these U.S. tax laws.” Thorn recommends that U.S. citizens with undisclosed overseas accounts contact an experienced tax attorney as soon as possible in order to discuss their rights and options. Thorn further explains, that “U.S. taxpayers with undisclosed overseas accounts should not take any more chances of being penalized and possibly imprisoned.

U.S. taxpayers with undisclosed overseas accounts who are concerned about the legal risks should talk to a tax attorney at Thorn Law Group as soon as possible for guidance and advice about the IRS’ Offshore Voluntary Disclosure Program (OVDP).

For additional information on the news that is the subject of this release, contact Kevin E. Thorn, Managing Partner of Thorn Law Group at 202-270-7273 or visit us at

About Thorn Law Group, PLLC: Thorn Law Group, PLLC is a law firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems.

Kevin E. Thorn
Managing Partner Thorn Law Group, PLLC

Thorn Law Group

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