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IRS Voluntary Disclosure

Experienced Boston Voluntary Disclosure Firm


The attorneys at Thorn Law Group have more than 80 years of combined experience working with individuals, businesses, foundations, trusts, banks and other entities in the Boston region and around the globe to successfully settle complex and sophisticated tax problems.  

As former government attorneys with the Internal Revenue Service and the U.S. Tax Court, our Massachusetts voluntary disclosure attorneys have the background and knowledge necessary to provide skilled advice and guidance regarding the Internal Revenue Service Offshore Voluntary Disclosure Program.  Under this IRS amnesty program, taxpayers may be able to avoid potential government prosecution and limit their exposure to the most severe financial penalties by voluntarily reporting prior tax violations associated with their foreign or offshore accounts.

2012 IRS Offshore Voluntary Disclosure Program

On January 9, 2012 the Internal Revenue Service announced the reopening of its Voluntary Disclosure Program for undisclosed foreign accounts and assets.  The IRS’s earlier amnesty programs, the 2009 Offshore Voluntary Disclosure Program and the 2011 Offshore Voluntary Disclosure Initiative, generated strong interest by taxpayers seeking to voluntarily report previously undisclosed offshore accounts.  

The IRS explains that the aim of the 2012 IRS Offshore Voluntary Disclosure Program remains the same as in its previous programs: “To bring taxpayers that have used undisclosed foreign accounts and undisclosed foreign entities to avoid or evade tax into compliance with United States tax laws.”  

While the new program imposes a higher penalty rate than the earlier program, it still provides strong incentives and benefits to encourage businesses and individuals to come forward to voluntarily disclose their offshore accounts.   

Unlike the earlier amnesty programs, the 2012 IRS Offshore Voluntary Disclosure Program does not have any set application deadlines.  While the government may not have established an end date for participation, our Boston voluntary disclosure firm cautions taxpayers that the IRS could change the terms of this program or elect to close the program at any time. Considering these uncertainties, taxpayers should not delay their participation or they run the risk of being shut out of this IRS amnesty initiative.

A Massachusetts Voluntary Disclosure Attorney Can Help

While making a voluntary disclosure under this amnesty program does not guarantee that the taxpayer will not be referred to the Department of Justice, the IRS has a long-standing policy of not making referrals for prosecution when the taxpayer makes a full and voluntary disclosure of previously undisclosed offshore accounts.   

Given this rare opportunity to avoid the risk of criminal prosecution and the fact that once the IRS opens an examination, the taxpayer is no longer eligible to participate in the Voluntary Disclosure Program. Taxpayers should discuss any undisclosed offshore accounts with an experienced Boston voluntary disclosure attorney.   

The legal team at Thorn Law Group concentrates on developing plans and strategies that help our clients come into and remain in compliance with all requirements associated with their foreign accounts and assets.  We have an in-depth understanding of the strict requirements, procedures and benefits associated with the IRS Offshore Voluntary Disclosure Program and use this knowledge to guide our clients through all phases of the program.

To discuss your situation with an experienced Massachusetts voluntary disclosure attorney, contact Kevin E. Thorn, Managing Partner, at ket@thornlawgroup.com or (617) 692-2989. You can also learn more about the IRS Offshore Voluntary Disclosure Program by reviewing the topics listed below:

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