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May 12, 2009 - Phil Hodgen

IRS statement on negotiating penalties for offshore accounts

irs-penaltiesThe IRS voluntary disclosure program (the FBAR amnesty) for offshore accounts is in full swing. One of the questions that comes up is whether the IRS will negotiate the penalties downward.

We appear to have a semi-official, nonbinding answer from a reliable source. IRS Criminal Investigation Division Chief Eileen Mayer appeared at the the May 9 Civil and Criminal Tax Penalties session of the American Bar Association Section of Taxation meeting in Washington, DC. Tax Notes Today, 2009 TNT 89-2, gives us the quote:

Asked about the possibility of negotiating the penalty amount on the civil side, Mayer said, “The penalty is what the penalty is. I don’t believe there is the intent to negotiate within the confines of the offshore accounts.”

Tax Notes Today is a pay service. Sorry I can’t link to the article. I get TNT through Lexis.

US Real Estate Investments Voluntary Disclosure