The Department of Justice and the Internal Revenue Service (IRS) have pursued for several years a well-publicized and successful enforcement campaign directed against U.S. taxpayers holding undisclosed offshore accounts. To take advantage of its deferred prosecution agreement with Swiss banking giant UBS A.G., as well as various related prosecutions of individual account holders, the IRS rolled out a special version of its voluntary disclosure program for holders of offshore accounts from March 2009 through Oct. 15, 2009. To date, the IRS has stated that about 15,000 taxpayers entered this special program, and that about another 3,000 taxpayers submitted voluntary disclosures after the special program ended.
The government repeatedly has stated that it will continue to pursue banks, account holders, and tax advisers involved in undisclosed offshore accounts. Further, IRS Commissioner Douglas Schulman has made several recent announcements that the IRS is likely to launch a new version of the special voluntary disclosure program for offshore accounts, more aggressive and onerous than the special program that closed in October 2009.
