News & Events

The IRS initiated a new National Research Program Initiative in November 2009 simply known as the Initiative: an industry wide detailed audit of employment taxes for 6,000 randomly selected businesses for the duration of the next three years. The intent of the Initiative has two aspects: ONE: assess systemic employment tax compliance; and TWO: collect assessments from delinquent employers.

In the wake of the UBS AG fallout and the closing of its Offshore Voluntary Disclosure Initiative on October 15, 2009, the IRS continues to wage its attack on offshore tax evasion. One IRS tactic is to issue an Information Document Request – or IDR – to taxpayers suspected of having unreported foreign bank accounts requesting documents and materials related to the foreign accounts. DC tax attorney Kevin Thorn discusses the potential for more IDRs to be issued as the result of information received by the IRS from UBS and the significant participation in the Voluntary Disclosure Initiative.

In the wake of the Internal Revenue Service (IRS) Offshore Settlement Initiative Voluntary Disclosure Program and UBS AG investigation, there will likely be a surge in IRS Information Document Requests focusing on offshore bank accounts.  Offshore tax evasion remains a top enforcement priority for the IRS, which will continue to step up pressure on U.S. taxpayers with undisclosed offshore accounts.  The Information Document Request will be the next step in the IRS’s enforcement strategy. 

Taxpayers who missed the deadline for the Internal Revenue Service (IRS) Offshore Settlement Initiative Voluntary Disclosure Program can still file a traditional Voluntary Disclosure under the IRS’s normal filing strictures.  It is clear that offshore tax evasion remains a top enforcement priority for the IRS and the IRS will continue to step up pressure on U.S. taxpayers with undisclosed offshore accounts.  Voluntary disclosure provides U.S. taxpayers with previously undisclosed offshore accounts a way to avoid the harshest penalties and potential criminal prosecution.