IRS Using Settlement Initiative To Expand Offshore Enforcement Efforts – May Effect Practitioner Community
Recently, the IRS released a streamlined questionnaire for taxpayers seeking to participate in the offshore voluntary disclosure settlement initiative. Based on the questions asked, it appears the IRS plans to use the information provided by account holders to expand its investigation into the suspected use of offshore bank accounts to evade taxes to include the bankers, accountants, return preparers, attorneys and others who may have advised the taxpayers regarding the accounts.
Specifically, the form letter issued by the IRS last week for use with offshore settlement initiative seeks names, dates and locations of meetings account holders had with professional advisers and investment managers.
No doubt the IRS will seek to use this information to establish a new round of investigation targets to possibly include tax professionals and return preparers. This is consistent with previous IRS practice,i.e., the recent prosecutions against tax professionals at KPMG and BDO Seidman.