Should I Stay or Should I Go? – Part 2

Answers to the Most Frequently Asked Questions Regarding Offshore Voluntary Disclosure Program

As a tax attorney specializing in the Offshore Voluntary Disclosure Program (OVDP), nary a day goes by that I don’t get a call from a person inquiring about the OVDP. The questions asked are relatively the same. After a while, I began to make a list of the most frequently asked questions. Below are my answers to them: (continued)

III. What are some of the criminal charges I might face if I don’t come in under OVDP and the IRS examines me?

Potential criminal charges include:

• Tax evasion: Tax evasion carries a prison term of up to five years and a fine of up to $250,000.

• Filing a false return: Filing a false return carries a prison term of up to three years and a fine of up to $ 250,000.

• Failure to file an income tax return: Failing to file an income tax return carries a prison term of up to one year and a fine of up to $ 100,000.

• Willfully failing to file an FBAR and willfully filing a false FBAR: Failing to file an FBAR carries a prison term of up to ten years and criminal penalties of up to $ 500,000.

Next:  Part 3 – IV. What kinds of assets does the 27.5% penalty apply to?

In accordance with Circular 230 Disclosure

As a former public defender, Michael has defended the poor, the forgotten, and the damned against a gov. that has seemingly unlimited resources to investigate and prosecute crimes. He has spent the last six years cutting his teeth on some of the most serious felony cases, obtaining favorable results for his clients. He knows what it’s like to go toe to toe with the government. In an adversarial environment that is akin to trench warfare, Michael has developed a reputation as a fearless litigator.

Michael graduated from the Thomas M. Cooley Law School. He then earned his LLM in International Tax. Michael’s unique background in tax law puts him into an elite category of criminal defense attorneys who specialize in criminal tax defense. His extensive trial experience and solid grounding in all major areas of taxation make him uniquely qualified to handle any white-collar case.

   

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