November 5, 2009

Noncompliance After the IRS Offshore Income Reporting Initiative - What Options Remain?

Journal of Taxation
Kevin E. Packman
Private Wealth Services Partner Kevin Packman published an article titled "Noncompliance After the IRS Offshore Income Reporting Initiative – What Options Remain?" in the Warren, Gorham & Lamont Journal of Taxation.

In the article, Mr. Packman discusses the diminishing options available to taxpayers who failed to disclose offshore accounts under the IRS Offshore Income Reporting Initiative. Mr. Packman advises that, despite expiration of the "amnesty" period, voluntary disclosure to the IRS remains the best option for unforthcoming taxpayers. However, a voluntary disclosure subsequent to the Initiative's October 15 conclusion will include greater penalties than a disclosure under the Initiative. The exactitudes of these penalties are not yet known, but Mr. Packman warns that, "the days of the kinder, gentler IRS have long passed." To read the full article, please visit the link below:

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