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The 2011 IRS Offshore Voluntary Disclosure Initiative

In February 2011, the IRS announced its 2011 Offshore Voluntary Disclosure Initiative (OVDI), a program that would allow those with offshore assets who had not previously declared and paid taxes on them to become current in their tax obligations. Motivated by the success of past disclosure programs and the need […]


Second Special Voluntary Disclosure Initiative

The IRS announced on February 8, 2011, a second voluntary initiative inviting taxpayers with hidden offshore assets to come forward. This initiative is intended to help people get current with their taxes related to offshore assets and will remain in place until August 31, 2011. Participants may face penalties ranging […]


IRS Criminal Investigation report shows aggressive prosecution

We regularly represent taxpayers, businesses and tax preparers in Texas and beyond facing potential tax-related criminal investigation or charges by the IRS Criminal Investigation division. This week, the IRS announced in a news release that it had released its fiscal year 2016 annual report of Criminal Investigation activities. Criminal defense […]

Tax Crimes

Offshore Accounts in Government Crosshairs

As the U.S. government looks for increased revenue, one of the most attractive places to look is where taxes that should be paid have not been paid. Since the 2009 voluntary disclosure initiative, which was very successful, and since recent legislative and policy changes of foreign governments such as Switzerland, […]


Legislative Change in Switzerland

For many decades, Switzerland has held the gold standard in banking secrecy. No one would know if you had accounts there and many investors with financial interests in the United States – U.S. citizens or otherwise – used this loophole to avoid taxation of large sums. The long-held tradition of […]


Law Makers Attack Offshore Tax Evasion with New Bill

A bill aimed at obtaining greater information from foreign banks about US citizens and corporations with overseas accounts was introduced recently in Congress. If passed, the new law would curb the use of offshore accounts by US citizens to shield assets from taxation and severely penalize those individuals and organizations […]


IRS Whistle-Blower on UBS Case

With $70 billion per year in uncollected taxes at stake, the Internal Revenue Service (IRS) is cracking down on offshore tax evasion. The concentrated effort began in earnest last year after an extensive investigation into the activities of the Swiss banking giant UBS AG uncovered the largest offshore tax evasion […]