Since the IRS opened its first Offshore Voluntary Disclosure Programme in 2009, it says that there have been more than 55,000 disclosures and that it has collected more than $9.9 billion. It also says that it has conducted a significant number of offshore related civil audits and pursued criminal charges which have resulted in the payment of tens of millions of dollars in unpaid taxes as well as significant volumes of fines. IRS Commissioner John Koskinen is quoted in the announcement as saying “The IRS receives more foreign account information each year, making it harder to hide income offshore. I urge taxpayers with international tax issues to come forward and get it right with the system”.
All of this resonates with the themes explored in DQ’s recent Tax Enforcement Conference whereby it was clear that the impact of automatic exchange of information initiatives are beginning to be felt as more and more financial services businesses are seeing the receipt of Tax Information Exchange requests and jurisdictions come under increased pressure to be co-operative. It also chimes with the topic addressed by DQ’s Leanne McKeown and Pinsent Mason’s Alan Sheeley as to how a financial services business might manage a crisis if a client is facing prosecution and public criticism on its tax affairs.
DQ’s Tax Enforcement team specialises in assisting clients with tax, regulatory and reputational issues arising from tax investigations and enforcement actions. Please contact Annemarie Hughes, Leanne McKeown or Sinead O’Connor to discuss how we can help if you find Lee Marvin, Telly Savalas or Charles Bronson at your door.