Undeclared Offshore Bank Accounts and International Tax Compliance

Our tax controversy lawyers are internationally recognized as leaders in the representation of taxpayers throughout the world in matters involving the ongoing and extensive efforts of the U.S. government to identify undeclared interests in foreign financial accounts and assets, voluntary disclosures, civil tax examinations, criminal tax investigations and criminal prosecutions.

We have represented literally hundreds and hundreds of U.S. taxpayers participating in various IRS Offshore Voluntary Disclosure Programs (OVDP), the Streamlined Foreign Compliance Procedures, Streamlined Domestic Offshore Compliance Procedures, Delinquent Filing Procedures and other forms of voluntary disclosures regarding foreign financial account values far exceeding billions of dollars in the aggregate. We also often represent individuals and estates who have opted out of the foregoing IRS programs or who are otherwise under examination for these issues.

We have the requisite knowledge and expertise to meaningfully assist in determining the proper path forward for each client, whether that path may lead to an IRS voluntary disclosure program or otherwise. Issues often present in these matters include the failure to report a beneficial or legal ownership interest in foreign financial accounts; unfiled, false or incomplete income tax returns, Foreign Bank Account Reports (FBAR) or other required information returns; unreported foreign trust, foundation or corporate structures; and estate and gift tax issues associated with undeclared offshore accounts or assets.

We are frequently consulted by other tax professionals, bankers, financial advisors, lawyers and others in these matters and often serve in a co-professional relationship in an effort to achieve the best possible resolution for our clients. Our criminal tax lawyers have represented numerous taxpayers involved in Grand Jury investigations, criminal prosecutions and, when beneficial for the client, the effective negotiation of plea agreements involving the alleged misuse of foreign entities to conceal legal and beneficial interests in foreign financial accounts and assets.

If you may have any potential undeclared interest in an offshore financial account or asset, we can help.