The Wall Street Journal has an interesting article this morning on the leak of information from HSBC to at least some tax authorities. The article is titled "Mass Leak of Client Data Rattles Swiss Banking."
Those U.S. taxpayers who thought they had a beneficial risk / reward ratio in staying out of the IRS voluntary disclosure program need to re-consider their model. The community of persons having potential inside access to tax haven bank data have to know by now that others may be interested in this data and may even pay handsomely for it. Indeed, simply because the IRS (or DOJ Tax, depending upon who is conducting the investigation) might get swamped and unable to process the information for tax collections (and hence rewards), such persons would probably want to get in line early.
I had a saying when I first began posting on offshore accounts and the voluntary disclosure policy - "Get in Line Brother." Those with undisclosed offshore accounts might want to take -- or at least reconsider -- that advice.
Jack Townsend offers this blog on Federal Tax Crimes principally for tax professionals and tax students. It is not directed to lay readers -- such as persons who are potentially subject to U.S. civil and criminal tax or related consequences. LAY READERS SHOULD READ THE PAGE IN THE RIGHT HAND COLUMN TITLE "INTENDED AUDIENCE FOR BLOG; CAUTIONARY NOTE TO LAY READERS." Thank you.
Friday, July 9, 2010
Leak From HSBC Suggests U.S. Taxpayers Continuing to Hide Offshore Assets Should Re-Think Their Model
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Amen! One has to wonder what the post October 15 2009 risk/reward ratio has now morphed into. There seems to be much speculation on Fbar penalties and other penalties as well.Clearly the IRS will be focused on these issues for much time to come. As you have stated before, it seems that the high end on the Fbar is 50% for one year. Is it not still is better to call on them than the vice versa?
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