You can call us today for a no cost professional tax consultation 1-866-700-1040 and speak directly to Tax Attorneys, CPA’s and Former IRS agents who are tax specialists for IRS Offshore Tax Issues and Voluntary Disclosures.

We have over 206 years of professional tax experience and over 60 years of working directly for the IRS.

We taught Tax Law at the IRS.

The Offshore Voluntary Disclosure Program is offered to those taxpayers with Offshore Bank Accounts or Assets Offshore.

New Offshore Program – The IRS penalty framework

The IRS penalty framework requires individuals to pay a penalty of 27.5 percent of the highest aggregate balance in foreign bank accounts, entities or value of foreign assets during the eight full tax years prior to the disclosure,up from 25 percent in the 2011 program.

Some taxpayers MAY be eligible for 5 or 12.5 percent penalties; these remain the same in the new program as in 2011. Call us for more details.

Persons must file all original and amended tax returns and include payment for back-taxes and interest for up to eight years as well as paying accuracy-related and/or delinquency penalties. Some of these penalties can be abated or reduced.

Persons face a 27.5 percent penalty, but taxpayers in limited situations can qualify for a 5 percent penalty.

Smaller offshore accounts will face a 12.5 percent penalty. Once again it is possible to reduce penalties.=

Persons whose offshore accounts or assets did not surpass $75,000 in any calendar year covered by the new OVDP will qualify for this lower rate.

As under the prior IRS Offshore Programs, taxpayers who feel that the penalty is disproportionate may opt instead to be examined. Sometimes you can reduce the penalties and interest.

The IRS recognizes that its success in offshore enforcement and in the disclosure programs has raised awareness related to tax filing obligations.  This includes awareness by dual citizens and others who may be delinquent in filing, but owe no U.S. tax.

The IRS is currently developing procedures by which these taxpayers may come into compliance with U.S. tax law. The IRS is also committed to educating all taxpayers so that they understand their U.S. tax responsibilities.
Pre-Clearance Phase of Voluntary Disclosure:

Faxed requests are made to the IRS Criminal Investigation Lead Development Center at (267) 941-1115.

IRS will need the taxpayers:

1. Name,

2. Date of birth,

3. Social security number and

4. Address
The  IRS Criminal Investigation ( CI ) will then notify taxpayers or their representatives via fax whether or not they have been cleared to make a voluntary disclosure using the Offshore Voluntary Disclosures Letter.

It should be emphasized that the Pre-clearance process does not guarantee a taxpayer acceptance into the Offshore Voluntary Disclosure Program.

The Issuance of the Offshore Voluntary Disclosure Letter

If the taxpayer chooses to submit a pre-clearance request, after the taxpayer receives a pre-clearance notification, the taxpayer will have 30 days from receipt of the fax notification to complete the Offshore Voluntary Disclosures Letter. It is always best to have a tax professional have your power of attorney so you never have to speak with the IRS.

If the taxpayer chooses to bypass the pre-clearance process, the taxpayer must mail the Offshore Voluntary Disclosures Letter to the following address:

Internal Revenue Service
Criminal Investigation
ATTN:  Offshore Voluntary Disclosure Coordinator
Philadelphia Lead Development Center
1-D04-100
2970 Market Street
Philadelphia, PA 19104

The IRS will review the offshore Voluntary Disclosures Letters and notify the taxpayer or representative by mail whether the voluntary disclosure has been preliminarily accepted or declined.

Complete Voluntary Disclosure Package

Once the voluntary disclosure has been preliminarily accepted, the taxpayer should send the full voluntary disclosure package to:

Internal Revenue Service
3651 S. I H 35 Stop 4301 AUSC
Austin, TX  78741
ATTN: 2011 Offshore Voluntary Disclosure Initiative

Opt Out Procedures – for Voluntary Disclosures

Taxpayers may request to opt out of the civil settlement structure of the 2009 Offshore Voluntary Disclosure Program or 2011 Offshore Voluntary Disclosure Initiative.

Taxpayers wishing to make a domestic voluntary disclosure that is not covered under this offshore initiative should contact their local IRS Criminal Investigation (CI) office to speak with a criminal investigator. Remember to do this by yourself is a big mistake.

IRS, Offshore – Voluntary Disclosure – IRS Tax Attorneys, Tax Lawyers, Former IRS Agents – Free Consultation – 1-866-700-1040