Lowrance Law, LLC

US Tax Investigations–Foreign Bank Accounts and Tax Havens

December 4, 2008

Thanks to Tax Prof Blog for A NYT Story on the expanded US Justice Department and IRS investigation of foreign banks, Credit-Suisse and HSBC and their private banking services. 

The new investigation relates to the present investigation into UBS Bank in Switzerland See See Prior Post.  The IRS and US Department of Justice (DOJ) are really looking for US citizens who are stashing money and assets in foreign accounts without reporting such accounts in filings with the IRS.  This investigation will come to fruition in the next several months to a year or more.  In this type of investigation, the government moves forward slowly and methodically.  The IRS and DOJ have to conduct the investigaitons using various international information gathering treaties and agreements.  

Don’t worry, however, the wheels of justice grind slowly.  The IRS and DOJ will eventually get some information about US citizens putting money in foreign bank accounts.  The information will be used to identify the people, find their tax filings, updated contact information and reported financial holdings.  The resulting case will go through either the civil or criminal process.  If you have a foreign account you have reported to the IRS, carefully plan your future.

Bill Lowrance
Your Virginia Tax Attorney
Lowrance Law LLC

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