This is a recurring question.  If you start down the amnesty path but you don’t like the outcome, can you be forced to accept the 20% of high balance as your penalty? Survey says . . . NO! Here’s the way the IRS says it in the voluntary disclosure FAQ: Q34. If, after making a [...]

I do an email newsletter.  Jell-O Shots.  (You can subscribe by going to the main page of our website and signing up there.  Please do!) Here is the latest one, which is all about the amnesty. Jell-O Shot Number 4 I wrote this to a lawyer friend (hi, Robin!) who needed to explain stuff to [...]

The foreign account amnesty is winding down to the last days. If you’re wondering about the payoff for the IRS, look no further. Here’s an example. An attorney and an accountant in Arizona have been indicted for setting up offshore tax structures. This is unrelated to any of my pending cases. But let me guess [...]

All you procrastinators out there, wondering what to do and wondering WHEN to do it? If you want coverage by the voluntary disclosure program currently under way for unreported bank accounts, you have to get to the IRS before they get to you.  I just had one of my applications bounced by the IRS.  Audit [...]

The Criminal Investigations offices are getting really fast at processing initial applications under the voluntary disclosure program.  This week’s speed demon reports:  Boston and Oakland.  Yay!  Think “days” rather than “weeks” to get clearance and your letter saying you’re eligible for the amnesty. The next stop on the the happy road of amnesty applications is [...]