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Hidden Foreign Bank Accounts And The IRS (June 2009)


Do you have an off shore bank account? Do you have an account in Switzerland or perhaps Liechtenstein? Have you failed to report this account to the IRS? Do you know that the IRS has an “amnesty” from criminal prosecution that will expire on September 23, 2009?

Information has been recently brought to my attention concerning undisclosed foreign bank account and undisclosed foreign entities. I believe it is very important for you to be aware of this information and to take immediate steps to protect yourself from exposure to IRS criminal prosecution. I am not saying that you will be prosecuted criminally if you do not take advantage of the IRS “amnesty”. You have potential exposure and you should take all necessary steps to protect yourself as soon as possible.

Basically, you must file at least six (6) years of amended US income tax returns, not just 3 years. You must also pay a 20% additional penalty together with interest. You must file Form TD F 90-22.1.

If you fail to comply with the filing of all required delinquent returns and appropriate forms, you run the risk of detection by the IRS and the imposition of substantial penalties, including the civil fraud penalty and foreign information return penalties as well as an increased likelihood of criminal prosecution.

If you comply with these IRS requirements on or before September 23, 2009, the IRS will not subject you to criminal prosecution. If you wait until after that date to file your returns, or you elect not to file additional returns, I can not assure you that you will not have criminal exposure. Why take the chance?

KEEP YOUR CONVERSATION CONFIDENTIAL! We will be happy to review your specific situation and to advise you whether or not to make a formal “voluntary disclosure” by making a direct contact with the IRS authorities, or to make a “quiet disclosure” by indirectly approaching the IRS. There are benefits and risks to either type of disclosure. Naturally, you will want to discuss your specific situation in total and complete privacy under the attorney-client privilege. Please remember that CPAs, Enrolled Agents and tax return preparers do not have privileged confidential communication where there is potential for criminal exposure. You need to talk to an attorney. Remember the September 23rd deadline!