{"id":18312,"date":"2010-12-29T00:00:00","date_gmt":"2010-12-29T00:00:00","guid":{"rendered":"https:\/\/getirshelp.com\/blog\/irs-offshore-amnesty-program\/"},"modified":"2026-07-24T22:01:24","modified_gmt":"2026-07-24T22:01:24","slug":"irs-offshore-amnesty-program","status":"publish","type":"post","link":"https:\/\/getirshelp.com\/blog\/irs-offshore-amnesty-program\/","title":{"rendered":"The IRS Offshore Amnesty Program and You"},"content":{"rendered":"

After 32 years of IRS work \u2014 and more than $100 million in resolved tax debt \u2014 I've seen just about every version of the problem you're dealing with. I'm Darrin Mish, a tax attorney in Tampa. Here's what you should know.<\/p>\n

If you have an offshore bank account, you should know that it is subject to tax. \u00a0If you are one of the many American taxpayers who have not declared your offshore assets in your tax returns, you might be able to do so in an amnesty program that the IRS is likely to have soon. \u00a0Click here to watch or read more information on IRS Back Taxes.<\/a><\/div>\n
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The IRS has held amnesty programs for offshore bank account holders before. \u00a0The first time was in 2003 which ended on April 15 that year. \u00a0During this limited amnesty program, the IRS reported that some $170 million in taxes, penalties and interests were recouped from taxpayers who participated. \u00a0The conditions of the amnesty program were that the taxpayer must divulge details of all persons or entities that helped or advised them in hiding their money in offshore accounts to avoid taxes. \u00a0Armed with such information, the IRS would pursue redress against such individuals or entities and shut down their operations. \u00a0In exchange, the IRS would not press criminal charges against the participating taxpayers.<\/div>\n
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The second amnesty program was held last year and ended on October 15. \u00a0This time, almost 15,000 taxpayers stepped forward to declare their assets in offshore accounts. \u00a0In the 2009 amnesty program, the IRS fixed 20% of the highest amount in the offshore bank accounts over the previous 6 year period (2002 to 2008) as a civil penalty. \u00a0Unfortunately, it so happened that during the period from 2002 to 2008, the equity values worldwide fell drastically. \u00a0For example, a balance of $1 million in an offshore account in 2007 might have been only worth $600,000 by the end of 2008. \u00a0But the civil penalty was still assessed on the $1 million balance, not $600,000. \u00a0This effectively raised the penalty rate from 20% to 33.3% (or $200,000 of $600,000).<\/div>\n
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Will there be another amnesty program declared soon? \u00a0It is highly likely. \u00a0Firstly the IRS Commissioner Doug Shulman gave weight to this possibility in his recent speeches. \u00a0Secondly, the IRS would rather give an amnesty in exchange for information on promoters of tax evasion schemes rather than have most taxpayers make a \u2018quiet disclosure\u2019. \u00a0A \u2018quiet disclosure\u2019 means the taxpayer simply submits amended returns, files the necessary forms and pays all back taxes and interests. \u00a0The IRS would have up to 6 years to call for an audit of such returns.<\/a> \u00a0It is unlikely that the IRS would have the means to audit all or even most of such \u2018quiet disclosures\u2019.<\/div>\n
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If you are contemplating participating in the next IRS amnesty program, it is best to consult a tax attorney (not an accountant) for advice first.<\/a> \u00a0Call us at (813) 229-7100 for a free consultation.<\/div>\n

Check out more Tax Related News<\/a> stories by clicking that link.<\/p>\n

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After 32 years of IRS work \u2014 and more than $100 million in resolved tax debt \u2014 I've seen just about every version of the problem you're dealing with. I'm Darrin Mish, a tax attorney in Tampa. Here's what you should know. If you have an offshore bank account, you should know that it is […]<\/p>\n","protected":false},"author":2,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"rop_custom_images_group":[],"rop_custom_messages_group":[],"rop_publish_now":"initial","rop_publish_now_accounts":[],"rop_publish_now_history":[],"rop_publish_now_status":"pending","footnotes":""},"categories":[591],"tags":[28],"class_list":["post-18312","post","type-post","status-publish","format-standard","hentry","category-irs-news","tag-irs-audit"],"_links":{"self":[{"href":"https:\/\/getirshelp.com\/blog\/wp-json\/wp\/v2\/posts\/18312","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/getirshelp.com\/blog\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/getirshelp.com\/blog\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/getirshelp.com\/blog\/wp-json\/wp\/v2\/users\/2"}],"replies":[{"embeddable":true,"href":"https:\/\/getirshelp.com\/blog\/wp-json\/wp\/v2\/comments?post=18312"}],"version-history":[{"count":1,"href":"https:\/\/getirshelp.com\/blog\/wp-json\/wp\/v2\/posts\/18312\/revisions"}],"predecessor-version":[{"id":21874,"href":"https:\/\/getirshelp.com\/blog\/wp-json\/wp\/v2\/posts\/18312\/revisions\/21874"}],"wp:attachment":[{"href":"https:\/\/getirshelp.com\/blog\/wp-json\/wp\/v2\/media?parent=18312"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/getirshelp.com\/blog\/wp-json\/wp\/v2\/categories?post=18312"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/getirshelp.com\/blog\/wp-json\/wp\/v2\/tags?post=18312"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}