Inconsistent chatter from a Sacramento-based 'Sconi attorney.

Tuesday, April 07, 2009

IRS Limited Offer on Unpaid Offshore Taxes Has Attorneys Scrambling


Tax attorneys are helping clients fess up to years of unpaid taxes on offshore account income through a new Internal Revenue Service settlement program offering a lower one-time payment for violators.

The IRS detailed the six-month program in March 23 internal memos, so attorneys are scrambling to help clients come clean and avoid steep penalties and potential criminal prosecution.

Taxpayers with offshore accounts totaling at least $10,000 traditionally have faced civil penalties of up to 50 percent of the account value or $100,000, whichever is greater, for willfully failing to file and report income from those accounts on a Report of Foreign Bank and Financial Accounts. In some cases, criminal penalties could also apply.

Under the settlement program, which involves filing up to six years of amended returns, the agency will cut the usual penalty to a one-time payment of 20 percent of the account value, or 5 percent for an inherited account.

Lawyers say taxpayers are signing up for the program, and more are likely to follow in the face of the IRS' declining tolerance for hiding offshore funds.

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