In an effort to promote full disclosures and tax compliance, the Internal Revenue Service has been sharing personal and financial U.S. taxpayer information with other foreign countries.  The exchange of such information could further provide U.S. agencies with sufficient evidence to open criminal investigations against U.S. taxpayers with undisclosed offshore banks accounts.

On Wednesday, September 28, 2011, U.S. authorities charged another India-American, Arvind Ahuja, for evading taxes through the HSBC India branch. These findings have heightened the pressure on HSBC, fueling the fire for the U.S. to build a strong case against the bank and it’s U.S. clients with undisclosed foreign accounts.

Grand Jury investigations are generally kept secret, but it has become clear that the Department Of Justice (“DOJ”) has eight more offshore banks now under formal grand jury investigations. The DOJ has not provided the public with the names of the alleged banks but it has been rumored that the agency has strong evidence against the banks in regards to conduct and/or information concerning taxpayers with undisclosed offshore accounts.

Even thought the deadline for the IRS’s 2011 Offshore Voluntary Disclosure Initiative has concluded, U.S. taxpayers with undisclosed offshore accounts still have the opportunity to come forward through the IRS’s traditional Voluntary Disclosure Program.

U.S. taxpayers with undisclosed offshore accounts have less than a week to take advantage of the IRS’s 2011 Offshore Voluntary Disclosure Initiative (OVDI).  The deadline for entering the “amnesty” program is Friday, September 9, 2011.  The OVDI may likely be the last opportunity for U.S. taxpayers with undisclosed offshore accounts to benefit from pre-determined penalties and reduced criminal exposure, but only if the taxpayer comes forward before the deadline.