With the IRS baring its teeth at anyone with an unreported offshore bank account, the rule of thumb was to submit to the agency's compliance program to avoid fines or prosecution. But after the amnesty program's expiration, tax litigators are not as ready to suggest their clients throw themselves under the IRS bus. Some are even opting out of the program that was so successful in the aftermath of the UBS investigation last year, which resulted in a $780 million fine for the bank and the revealing of American tax dodgers.
September 27, 2010 at 12:00 AM
1 minute read
The original version of this story was published on Law.Com
With the Internal Revenue Service baring its teeth at anyone with an unreported offshore bank account, the rule of thumb was to submit to the agency’s compliance program to avoid prosecution or excessive fines.
But after the expiration of an amnesty program, tax litigators are not as ready to suggest their clients throw themselves under the IRS bus. Some are even opting out of the program that was so successful in the aftermath of the UBS investigation.
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