New IRS Unit Dedicated to Investigating U.S. Taxpayers with Undisclosed Offshore Accounts

The IRS recently reaffirmed its commitment to combating offshore tax evasion by forming a new elite unit of professionals dedicated to investigating and auditing offshore tax evasion by U.S. taxpayers.   Taxpayers with undisclosed foreign accounts should take careful notice of the IRS’s commitment of resources to a long-term strategy for pursuing unreported income and assets kept in undisclosed offshore accounts.

The new IRS unit will be comprised of auditors and professionals with specialized experience in investigating complex cross-border transactions and multi-national business structures.   The group will be a part of the IRS Large and Mid-Size Business division and will be a part of LMSB’s global high-wealth industry office.   The global high-wealth industry office will be responsible for monitoring and examining wealthy individual U.S. taxpayers as well as businesses and other entities suspected of offshore tax evasion.

In the short-term, the unit will provide much needed assistance to an estimated 10,000 cases related to the investigation of Swiss-banking giant UBS AG – including the 4,450 taxpayers UBS will provide to the IRS plus the thousands of taxpayers anticipated to participate in the IRS’s offshore account voluntary disclosure initiativeU.S. taxpayers with undisclosed accounts in foreign banks, such as UBS, have just two weeks – or until September 23, 2009 – to make a voluntary disclosure of their offshore accounts to the IRS or risk facing increased monetary penalties and potential criminal prosecution.

The new IRS unit was created in part to deal with the offshore settlement initiative; however it will play a larger role beyond the UBS investigation.   The move signals an ever-increasing priority in the IRS offshore tax evasion enforcement strategy – aggressively pursuing individual U.S. taxpayers with undisclosed foreign accounts.