News & Events

On April 16, 2009, a federal judge in Denver granted a Justice Department request to serve a “John Doe” summons on payment processor First Data Corporation (“First Data”).  The “John Doe” summons seeks the names of all First Data clients that allegedly used First Data to transfer the proceeds of credit and debit card transactions to offshore accounts since 2002.  

On March 26, 2009 the IRS provided guidance to its field agents on how to deal with U.S. taxpayers who own interests in foreign (offshore) financial accounts that they have previously not disclosed to the IRS.  Failure to disclose such accounts to the IRS is punishable by a heavy fine and, in some cases; criminal charges may be brought against the taxpayer.  However, IRS Commissioner Douglas Schulman announced if these taxpayers come forward and divulge all of the information regarding their offshore accounts they can expect significant penalty relief. The penalty relief portion of the voluntary disclosure program will only be available to taxpayers who come forward within the next six months, or by September 26, 2009.

The IRS and the IRS Office of Professional Responsibility will be looking at changing the contingency section of Circular 230.