August 23, 2013

Crackdown on Tax Compliance

Holland & Knight Tax Compliance Blog
Kevin E. Packman

On August 23, 2013, Laura Saunders wrote an article titled, "Offshore-Adviser Plea Marks a Shift in Tax Crackdown," which appeared in The Wall Street Journal. The below chart accompanied the article and is noteworthy because it reflects more US taxpayers have been criminally charged since 2009 as a result of undeclared foreign accounts, than have pled guilty or been found guilty. This indicates more such pleas or verdicts are likely to be announced in the coming months, not just from the ongoing examinations but from future examinations, as the US continues to receive information from foreign banks.

Under Pressure

Since 2009, U.S. officials have cracked down on undeclared offshore accounts.

  • U.S. taxpayers criminally charged: 86
  • Firms or advisers criminally charged: 35 
  • Guilty pleas: 64 
  • Guilty verdicts: 10 
  • Average account balance at its peak: $6.8 million* 
  • Participants in IRS offshore limited-amnesty program: More than 38,000 
  • IRS collections from limited-amnesty program: $5.5 billion, with $5 billion more to come 

*Excludes some atypical cases

Sources: Jack Townsend, Federal Tax Crimes; IRS; Bryan Skarlatos, Kostelanetz & Fink

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