I'm Darrin Mish. For 32 years I've practiced federal tax litigation — routine audits, Tax Court cases, and everything in between. If you're facing an IRS issue, here's what you need to know first.
There are numerous banks that have deferred prosecution agreements with the U.S. government. The numbers keep growing.
A deferred prosecution agreement serves to delay action on a criminal charge. Action is set aside until sometime in the future. The case could be dismissed at the end of the deferred time frame if no additional crimes are committed. Typical time frames for a delayed prosecution can be from six months to a year.
The IRS has a long list of offshore banks, with US accounts that it’s keeping its eye on. The result is that banks all over the world want to know if they’re actually in compliance with the IRS. There is a voluntary disclosure program that the banks can utilize.
The IRS’s program continues to grow in size and popularity. It’s their attempt to put a tighter wrap on tax evasion at the corporate level. In a nutshell, the Voluntary Disclosure Program is designed to help individuals and corporations avoid criminal and civil penalties.
If you have a foreign bank account and it was never disclosed to the IRS, you may be a candidate the program. Additional advice may come at the hands of a qualified tax professional.
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