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Before You Apply for Tax Amnesty

Discuss Your Situation with a Massachusetts IRS Amnesty Attorney

The IRS Amnesty Programs and Voluntary Disclosure Program provide taxpayers who have violated U.S. tax laws with an opportunity to avoid the harshest civil and criminal penalties.  However, taxpayers need to carefully consider all options before electing to participate in such programs.  There are many caveats associated with these types of programs and taxpayers should have their case thoroughly evaluated by a skilled tax attorney to determine whether an amnesty program is appropriate for their particular circumstances.   

The Massachusetts IRS amnesty attorneys at Thorn Law Group have extensive experience advising clients in the Boston area and across the United States throughout all stages of the IRS Offshore Voluntary Disclosure Program.  Our lawyers are former IRS attorneys with a vast understanding of foreign banking operations.  We use our skills and knowledge to carefully review and analyze our clients’ banking and financial statements to determine whether voluntary disclosure represents the best tax relief option for our clients.

Understand the Program Requirements

The IRS Voluntary Disclosure Program offers taxpayers the opportunity to come into compliance with U.S. tax laws by making a voluntary disclosure of previously undisclosed offshore accounts.  This program is available to individuals, corporations, trusts, partnerships and other entities in the Boston region, throughout the nation and abroad.  

Based upon the strong interest generated in its 2009 and 2011 disclosure programs, the IRS reopened its Offshore Voluntary Disclosure Program for undisclosed foreign accounts on January 9, 2012.  While this program is an open-ended initiative, meaning there is no set deadline to apply, the IRS may elect to change or end the program at any time.  Given this uncertainty, taxpayers should not delay in discussing concerns about their offshore accounts with an experienced Massachusetts IRS amnesty attorney.

Individuals and entities considering making a voluntary disclosure under the IRS amnesty program should be aware that the process is highly complex and participants are subject to strict eligibility rules and guidelines.  In the event the IRS has already opened an examination of a taxpayer, that taxpayer is no longer eligible to participate in the program.  Additionally, once the taxpayer is accepted into the program, the taxpayer must be willing to cooperate fully with the IRS and comply with all conditions associated with the program. 

Be Aware of all Penalties

While taxpayers may plan to enter the Voluntary Disclosure Program in order to escape the risk of criminal prosecution and severe civil penalties, they need to be aware that even if they are accepted into the program they will still be required to pay substantial penalties to the U.S. government.  In general, participants in the program will be subject to a penalty of 27.5 percent of the undisclosed offshore account highest year’s aggregate balance during the period covered by the voluntary disclosure.  In certain instances a taxpayer may be eligible for an exception which will lower the amount of this penalty.  Taxpayers must also pay back all taxes and interest for a period of up to eight years along with all accuracy related and/or delinquency penalties.  Additionally, under a voluntary disclosure, the taxpayer is required to provide the IRS with all original and amended tax returns and make payments for taxes, interest and accuracy related penalties.

Contact Thorn Law Group Today

The Massachusetts IRS amnesty attorneys at Thorn Law Group have extensive experience navigating clients through all phases of the IRS review process associated with the Voluntary Disclosure Program.  

We are also highly familiar with the program’s eligibility requirements for individual taxpayers and entities seeking to avoid substantial civil penalties and potential criminal prosecution resulting from their failure to disclose offshore accounts.  While we understand that taxpayers who have failed to disclose offshore accounts may want to make a voluntary disclosure, we caution you to discuss your situation with a qualified tax attorney before doing so.  

The legal team at Thorn Law Group offers confidential consultations and will carefully review your case to identify the best approaches available to bring your offshore account into compliance with U.S. laws and regulations.  Managing Partner Kevin E. Thorn offers confidential consultations and can be reached at (617) 692-2989.

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