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5 Real-Life Examples of Taxpayers Avoiding Substantial Penalties Through Voluntary Disclosure

Articles/News, Offshore Account Update

Posted on September 23, 2020 |

The Internal Revenue Service’s (IRS) Voluntary Disclosure Practice affords U.S. taxpayers the opportunity to avoid substantial liability in the event that they have failed to timely disclose their offshore accounts—as required by federal law. The Voluntary Disclosure Practice is not available to all taxpayers in all circumstances, and it does not afford the ability to completely avoid liability in most cases, but it can help taxpayers avoid tens of thousands, hundreds of thousands or even millions of dollars in IRS penalties in many circumstances.

How Can a Boston International Tax Attorney Help with Offshore Account Disclosure?

If you are wondering whether you should utilize the IRS’ Voluntary Disclosure Practice, you should speak with a Boston international tax attorney promptly. Here are five real-life examples of cases in which Kevin E. Thorn, Managing Partner of Thorn Law Group, has helped U.S. taxpayers avoid substantial penalties for offshore account disclosure violations:

1. Indian Family Obtains 50 Percent Reduction in Penalties on Hundreds of Thousands of Dollars of Offshore Assets

Mr. Thorn represented an Indian family with regard to the disclosure of the family’s offshore accounts to the IRS. Mr. Thorn guided the family through the IRS’ Offshore Voluntary Disclosure Program (OVDP), a predecessor to the current voluntary disclosure options, establishing compliance and securing a fifty-percent reduction in the penalties owed as a result of the family’s untimely disclosure.

2. American Family Obtains Inheritance from Offshore Account and Completes Compliant Voluntary Disclosure

Mr. Thorn represented an American professional living overseas and her siblings after their mother left them a multi-million-dollar inheritance in a French bank account. After the bank initially stated that the children of the deceased accountholder would not be permitted to access the account, Mr. Thorn was able to convince the bank to release the funds. Mr. Thorn subsequently assisted his clients in making a fully-compliant disclosure through the IRS’ Voluntary Disclosure Practice and filing the requisite FBARs.

3. Couple Saves More Than $1.1 Million After Withdrawal from OVDP

Mr. Thorn represented a husband and wife who were facing substantial liability for taxes and penalties due to the untimely disclosure of their offshore accounts. After initiating a filing under the OVDP, the couple withdrew from the process and ultimately ended up in the U.S. Tax Court. Mr. Thorn entered the case and was able to negotiate a settlement that saved his clients more than $1.1 million.

4. Australian Couple Living in the U.S. Avoids Penalties for Failure to Disclose Offshore Accounts

Mr. Thorn represented an Australian couple living in the United States who needed to disclose their Australian accounts to the IRS. Mr. Thorn guided the husband and wife through the disclosure process and helped them establish compliance while avoiding penalties for non-disclosure.

5. Foreign Business Owner Avoids Removal and Serves Minimal Time for Substantial Tax Violations

Mr. Thorn represented a foreign business owner who had failed to disclose more than $2 million in offshore assets and who had failed to file federal tax returns for over 15 years. While the business owner was facing a multi-year prison sentence and removal (deportation) from the U.S., Mr. Thorn was able to negotiate a deal that allowed the business owner to remain in the United States and serve just six months.

Speak with Boston International Tax Attorney Kevin E. Thorn, Managing Partner of Thorn Law Group

Do you have questions about the IRS’ Voluntary Disclosure Practice for offshore accounts? To speak with Boston international tax attorney Kevin E. Thorn, Managing Partner of Thorn Law Group in confidence, call 617-692-2989, email ket@thornlawgroup.com or contact us online today.


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