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The Panama Papers

Have you received a phone call from the Internal Revenue Service (IRS) asking you to come in for an interview? Are you the subject of an IRS examination or target of an IRS criminal case? In light of the release of the Panama papers, we are likely to see more activity in the international enforcement area. Internal tax enforcement is a top priority for the IRS for both civil and criminal tax cases. The IRS has received a substantial amount of information concerning undisclosed offshore accounts and foreign entities from various sources including the IRS Offshore Voluntary Disclosure Program and the IRS Whistleblower program, and the IRS is now looking into this vast source of information to examine and investigate taxpayers who are non-compliant. It has now been approximately seven years since the IRS first launched the Offshore Voluntary Disclosure Program in 2009 and eight years since the Department of Justice’s case against the Swiss Bank UBS. The argument that “I did not know that I had to report my foreign account” may no longer play well, and the landscape arguably has changed. The IRS believes that there is a tremendous amount of offshore money that is not being reported and has developed offshore compliance options for taxpayers with undisclosed foreign accounts or unreported foreign source income.