News & Events

On Tuesday, November 17, 2009, the Internal Revenue Service (IRS) and U.S. Department of Justice (DOJ) released information on the highly-publicized Settlement reached with Swiss banking giant UBS AG (UBS). According to recently released information, over 14,700 U.S. taxpayers agreed to participate in the Offshore Settlement Initiative Voluntary Disclosure Program, instituted as a way for taxpayers to disclose and avoid the harshest penalties.  Further, the IRS has disclosed the criteria set forth in the “John Does” Settlement that has led UBS to turnover thousands of U.S. taxpayer clients.  The criteria serves as a guide to future investigations as the IRS and DOJ continue to investigate and prosecute U.S. taxpayers who fail to disclose their offshore assets to the U.S. government.

Kevin E. Thorn will be a panelist at the William & Mary Tax Conference this November in Virginia.  Mr. Thorn will participate with the Deputy Director of the IRS’s Office of Professional Responsibility, Carolyn Gray.

As anticipated, undisclosed government sources have confirmed that the IRS is extending the deadline for U.S. taxpayers with undisclosed foreign bank accounts to come forward and participate in the special voluntary disclosure settlement initiative.

With the October 15, 2009 Offshore Account Voluntary Disclosure deadline fast approaching, proper reporting of foreign corporate interests and dividend disclosures has become a top IRS priority. Notably, the IRS has stepped up pressure on U.S. taxpayers to come forward and correct all failures to properly disclose their ownership interest in foreign corporations.  It’s not just a failure to file a Form TD F 90-22.1 – Report of Foreign Bank and Financial Accounts (FBARs) – that can get taxpayers in trouble.  Taxpayers are also required to disclose ownership, acquisitions and dispositions of foreign corporate stock on a Form 5471 – Information Return of U.S. Persons with Respect to Certain Foreign Corporations. 

Kevin E. Thorn will be giving the UBS Offshore Account Update on Voluntary Disclosures at the upcoming ABA Tax Section, Civil & Criminal Penalties Committee Meeting in Chicago.