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IRS Offers Second Chance to Taxpayers with Undeclared Foreign Holdings
The IRS has “moved East” in its attack on foreign banks and their U.S. customers with undisclosed offshore accounts. On Jan. 26, the DOJ indicted Vaibhave Dahake, an Indian-American businessman in New Jersey, for conspiring with several bankers at “an international bank” to maintain undisclosed accounts with the bank's offshore division, and thereby avoid his U.S. tax obligations. Press reports have identified that international bank as global banking giant HSBC, which has substantial operations in India.
Many observers have long suspected that Asia (particularly India, Hong Kong, Singapore and Korea), as well as Israel and other places outside Europe, are now “where the money is,” and that the number of foreign accountholders in these places dwarfs even the 52,000 who reportedly had accounts with Swiss bank UBS at the time of its tax-evasion controversy in 2008. The IRS is also said to be sifting through the information provided by taxpayers who already made voluntary disclosures to identify other banks to which some UBS accounts were transferred. These institutions are apparently also under scrutiny.
On Feb. 8, shortly after Dahake's indictment, IRS Commissioner Douglas Shulman announced the 2011 Offshore Voluntary Disclosure Initiative (OVDI), a second voluntary disclosure program for those U.S. taxpayers who still have undisclosed foreign holdings. Like the program that ended on Oct. 15, 2009, the new program not only provides a means to avoid criminal prosecution, but also gives those who participate certainty as to their maximum civil penalty exposure.
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