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Hiring an IRS Voluntary Disclosure Attorney

Taxpayers can Face Severe Civil and Criminal Penalties

The legal team at Thorn Law Group has an extensive understanding of the complex laws and procedures governing offshore accounts and voluntary disclosures. We regularly provide advice and assistance to individual taxpayers, trusts, businesses and other entities in the Boston region, across the United States and overseas who are required to comply with the strict U.S. reporting requirements governing offshore accounts and foreign assets.    

As former IRS attorneys, we understand the gravity of the consequences that can arise when taxpayers holding an interest in or signature authority over certain offshore accounts fail to properly disclose their accounts to the IRS on their annual tax return.  We are also acutely aware of the serious civil and criminal penalties the government can impose upon taxpayers who fail to file required FBAR (Report of Foreign Bank and Financial Accounts) forms by the annual June 30th deadline.   

Civil penalties for willfully failing to file the FBAR can be severe and include:  

  • the greater of $100,000 dollars or,
  • 50 percent of the balance of the foreign account for each willful violation.  

Even if the government finds that the taxpayer did not act willfully, the civil penalty can be as high as $10,000 dollars per violation.  

In addition to civil fines, taxpayers who fail to file an FBAR can be subject to invasive criminal investigations leading to a felony prison term of up to five years and/or criminal penalties of up to $250,000 dollars (these penalties can increase to $500,000 dollars and/or 10 years in prison if the taxpayer has violated other laws).

Taxpayers Need an Experienced Massachusetts IRS Voluntary Disclosure Attorney

Taxpayers may be able to avoid criminal prosecution and the harsh civil penalties stemming from the failure to properly report their offshore accounts by participating in the IRS Offshore Voluntary Disclosure Program.  Individuals and businesses in the Boston area and the greater New England region considering making a voluntary disclosure should discuss their situation with an experienced Massachusetts IRS voluntary disclosure attorney to determine whether this federal amnesty program is appropriate for their particular circumstances.  

The IRS reopened its Voluntary Offshore Disclosure Program in 2012 in a continuing effort to encourage taxpayers with undisclosed offshore accounts to come forward and voluntarily report their foreign accounts and assets. While this amnesty program offers significant incentives—the possibility of reduced civil penalties and no criminal prosecution—taxpayers need to make certain that they understand how the program’s terms and conditions apply to their specific situation before they choose to make a voluntary disclosure.  

It is important that taxpayers are represented by experienced legal counsel who fully understand U.S. tax laws and regulations and are able to fully assert and protect important legal rights and privileges, including the attorney-client privilege, while participating in the program.   

Let Us Help you Navigate the Intricacies of the Voluntary Disclosure Program

The attorneys at Thorn Law Group are highly skilled in explaining and guiding clients through the intricate processes and procedures associated with the Voluntary Disclosure Program.  We leverage our 30-plus years of combined tax law experience to carefully evaluate our clients’ offshore tax issues to determine whether, and the extent to which, our clients will benefit from participating in this IRS amnesty program.  

By handling hundreds of voluntary disclosure cases across the U.S. and abroad, we have an in-depth understanding of the various fines and penalties that the government can impose upon different categories of taxpayers under the program.  We also recognize that there are certain circumstances where making a voluntary disclosure will not be in the best interest of the client.  In these situations, a Massachusetts IRS voluntary disclosure attorney at our firm works closely with our clients to identify the best alternatives available outside of the program to successfully resolve their offshore tax issues.

To learn more about the offshore account and voluntary disclosure services offered by Thorn Law Group, contact Kevin E. Thorn, Managing Partner of Thorn Law Group, at ket@thornlawgroup.com or (617) 692-2989.

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