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.
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
LexisNexis® and Bloomberg Law are third party online distributors of the broad collection of current and archived versions of ALM's legal news publications. LexisNexis® and Bloomberg Law customers are able to access and use ALM's content, including content from the National Law Journal, The American Lawyer, Legaltech News, The New York Law Journal, and Corporate Counsel, as well as other sources of legal information.
For questions call 1-877-256-2472 or contact us at [email protected]