The clock is ticking on this tax amnesty program provided by the IRS.
Countries from around the world have disclosed or are in the process of disclosing United States account holder information. If a taxpayer is caught before entering OVDI / OVDP the penalties are draconian. Penalties likely include criminal prosecution.
If the taxpayer has offshore accounts or properties, it is critical that the taxpayer speak with a tax attorney and not an accountant. The accountant privilege does not apply to criminal proceedings. However, the attorney-client privilege does apply to criminal proceedings. The accountant could be subpoenaed to testify against the taxpayer at the criminal trial.
Philip Falco, CPA, Juris Doctor – Honors will work on your case to gain acceptance in OVDI / OVDP.
Quiet disclosures are not the answer. This is where a taxpayer begins to file proper schedules on his or her tax return without entering OVDI / OVDP. The IRS has specifically reserved the right to pursue criminal prosecution in these cases.
Because of the vast disclosures from foreign countries, participation in OVDI / OVDP is becoming more difficult every day.
The disclosures required for OVDI / OVDP are massive and must be done precisely. The worst fear would be accusation of a half-truth facing criminal prosecution.
We can prepare the required amendments to your returns and prepare the complete package to the IRS as required by OVDI / OVDP.
In the opinion of Philip Falco, CPA, Juris Doctor, the offshore initiative is the most significant tax development since the 1986 revisions to the internal revenue code that cracked down on tax shelters (revisions to passive activities and at-risk tax rules).
See our page on OVDP / OVDI