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ARTICLE · 24 FEBRUARY 2011

IRS Offers Second Chance To Disclose Hidden Offshore Accounts

Davies Ward Phillips & Vineberg LLP
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The IRS has announced a new amnesty program for U.S. persons with undisclosed foreign accounts or entities. U.S. persons with foreign accounts are required to report the existence of the accounts annually on Form TD F 90-22.1.

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Abraham Leitner
Abraham Leitner
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The IRS has announced a new amnesty program for U.S. persons with undisclosed foreign accounts or entities. U.S. persons with foreign accounts are required to report the existence of the accounts annually on Form TD F 90-22.1.1 Other reporting requirements apply to interests owned by U.S. taxpayers in foreign entities. A failure to report the existence of a foreign account can result in stiff civil penalties and may constitute a criminal offense.2 The IRS has greatly increased its enforcement efforts in this area and, following its highly publicized indictment of UBS in 2008, is actively pursuing investigations of other financial institutions that cater to U.S. taxpayers who are hiding accounts overseas.

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