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2015 UBS Probe Poses Threat to US Owners of Undisclosed UBS Accounts

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This week, UBS Group AG confirmed that it was under a new investigation over whether the Switzerland bank sold unregistered securities to US taxpayers in violation of US law. This article will discuss the new UBS probe and the threat it poses to US owners of undisclosed UBS accounts who never went through an offshore voluntary disclosure. This article is not intended to convey tax or legal advice.

Prior Investigations and 2009 Deferred-Prosecution Agreement

The 2015 bearer bond investigation of UBS is the latest in the series of DOJ investigations of UBS. Previously, in 2009, as a result a landmark DOJ victory that started the today’s rout of bank secrecy laws throughout the world, UBS paid a $780 million dollar fine and disclosed 250 previously undisclosed UBS accounts of US taxpayers to the DOJ (some of the owners of these undisclosed UBS accounts were later criminally prosecuted by the IRS). The bank promised that it would be compliant with US law under its deferred-prosecution agreement with the DOJ. The agreement expired in October, 2010. This was a critical agreement for the US owners of undisclosed UBS accounts, and we will come back to this subject below.

In addition to the deferred-prosecution agreement in 2009, UBS also settled an antitrust case in 2011 concerning the municipal-bond investments market, and resolved a 2012 DOJ investigation involving alleged rigging of the London interbank offered rate (Libor). UBS was granted an agreement to extend the term of its non-prosecution deal in the latter investigation until later this year. Additionally, in a probe not involving the DOJ, UBS paid US, UK and Swiss authorities nearly $800 million in November to settle allegations that they did not have satisfactory controls to prevent traders from attempting to rig Forex dealing.

The DOJ also has reportedly also opened a new investigation concerning certain currency-linked structured products sold by UBS. International tax attorneys who worked with undisclosed UBS accounts for their US clients in the past know how common it was for UBS to sell these products to their US clients.

The 2015 UBS Investigation

As noted above, the new investigation is being conducted by the U.S. Attorney’s Office for the Eastern District of New York and from the U.S. Securities and Exchange Commission. UBS stated in its fourth-quarter report, “In January 2015, we received inquiries from the U.S. Attorney’s Office for the Eastern District of New York and from the U.S. Securities and Exchange Commission, which are investigating potential sales to U.S. persons of bearer bonds and other unregistered securities.” UBS added that it was cooperating with the authorities in the probes. According to various new sources, the bank is also being probed as to whether the alleged sales occurred while the bank was under DOJ supervision from its earlier 2009 tax evasion case.

Bearer bonds can be redeemed by anybody physically holding them. Because of the ease with which these instruments can be transferred, they are a potentially useful tool for enabling individuals to hide assets and evade taxes. While bearer bonds were not deposited on undisclosed UBS accounts, some US owners of undisclosed UBS accounts were owners of these unregulated instruments.

Undisclosed UBS Accounts and the 2015 UBS Investigation

According to various sources, if UBS is found to have breached the agreement by selling the unregistered bearer bonds to US persons in violation of US law during the time period in which the agreement was still in effect, it is possible that the DOJ will prosecute the bank under the original conspiracy charge, in addition to filing new charges and penalties.

The significance of this scenario lies in the fact that there may still be US taxpayers with undisclosed UBS accounts (whether owned directly, indirectly or constructively). Many of these taxpayers were trying to hide in the relative safety of the UBS 2009 Deferred-Prosecution Agreement, hoping that the worst was over for UBS.

Moreover, because UBS was classified as a Category 1 bank, it could not participate in the DOJ Program for Swiss Banks. This gave a wrong type of encouragement to some US owners of undisclosed UBS accounts not to come forward and go through a voluntary disclosure program.

In reality, however, due to the fact that UBS was the first bank that succumbed to the pressure from the US DOJ and disclosed previously undisclosed UBS accounts owned by US persons, the DOJ’s deal with UBS was relatively mild compared to the later penalties on other large Swiss Banks (such as Credit Suisse). Hence, there is a great incentive for the DOJ to re-open the investigation into UBS to force the bank to pay an amount equivalent to its other Swiss peers.

This means that, if the 2015 investigation is successful and the DOJ can get around the 2009 Deferred-Prosecution Agreement, the UBS may, in a new deal with DOJ, conduct a wholesale disclosure of the US owners of undisclosed UBS accounts – not only the current owners, but also the US owners who had undisclosed UBS accounts in the years 2008-2010.

What Should the US Owners of Undisclosed UBS Accounts Do?

Thus, the 2015 DOJ investigation of UBS could have disastrous consequences for US persons who owned undisclosed UBS accounts between the years 2008 and the present time. The premature disclosure of undisclosed UBS accounts may foreclose very important voluntary disclosure options for the US owners of these undisclosed UBS accounts. The subsequent investigations by the IRS may result in draconian civil penalties and even criminal prosecutions.

This is why US persons who owned undisclosed UBS accounts should contact an experienced international tax attorney to discuss their voluntary disclosure options as soon as possible.

Contact Sherayzen Law Office for Help with Your Undisclosed Foreign Accounts

If you are have not disclosed your foreign accounts (including undisclosed UBS accounts) to the IRS, you are advised to immediately contact the experienced international tax law firm of Sherayzen Law Office, Ltd. For many years now, we have been helping US taxpayers like you to bring their US tax affairs into full compliance, and we can help you.

Contact Us to Schedule Your Initial Consultation! Remember, contacting Sherayzen Law Office is Confidential!

Abusive Tax Shelters on the IRS “Dirty Dozen” List of 2015

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On February 3, 2015, the IRS said using abusive tax shelters and structures to avoid paying taxes continues to be a problem and remains on its annual list of tax scams known as the “Dirty Dozen” for the 2015 filing season.

“The IRS is committed to stopping complex tax avoidance schemes and the people who create and sell them,” said IRS Commissioner John Koskinen. “The vast majority of taxpayers pay their fair share, and we are warning everyone to watch out for people peddling tax shelters that sound too good to be true.”

Compiled annually, the “Dirty Dozen” lists a variety of common scams that taxpayers may encounter anytime but many of these schemes peak during filing season as people prepare their returns or hire people to help with their taxes.

Abusive tax shelters are classified as illegal scams and can lead to significant penalties and interest and possible criminal prosecution. IRS Criminal Investigation works closely with the Department of Justice (DOJ) to shutdown scams and prosecute the criminals behind them.

Abusive Tax Shelters

Abusive tax shelters have evolved from simple structuring of abusive domestic and foreign trust arrangements into sophisticated strategies that take advantage of the financial secrecy laws of some foreign jurisdictions and the availability of credit/debit cards issued from offshore financial institutions.

IRS Criminal Investigation (CI) has developed a nationally coordinated program to combat these abusive tax shelters. CI’s primary focus is on the identification and investigation of the promoters of the abusive tax shelters as well as those who play a substantial or integral role in facilitating, aiding, assisting, or furthering the abusive tax shelters, such as accountants or lawyers. Just as important is the investigation of investors who knowingly participate in abusive tax shelters.

What are these abusive tax shelters? The Abusive Tax Schemes program encompasses violations of the Internal Revenue Code (IRC) and related statutes where multiple flow-through entities are used as an integral part of the taxpayer’s scheme to evade taxes. These abusive tax shelters are characterized by the use of Limited Liability Companies (LLCs), Limited Liability Partnerships (LLPs), International Business Companies (IBCs), foreign financial accounts, offshore credit/debit cards and other similar instruments. The abusive tax shelters are usually complex involving multi-layer transactions for the purpose of concealing the true nature and ownership of the taxable income and/or assets.

Whether something is “too good to be true” is important to consider before buying into any arrangements that promise to “eliminate” or “substantially reduce” your tax liability. If an arrangement uses unnecessary steps or a form that does not match its substance, then that arrangement may be classified as abusive tax shelter. Another thing to remember is that the promoters of abusive tax shelters often employ financial instruments in their schemes; however, the instruments are used for improper purposes including the facilitation of tax evasion.

Abusive Tax Shelters: Misuse of Trusts

Trusts also commonly show up in abusive tax shelters. They are highlighted here because unscrupulous promoters continue to urge taxpayers to transfer large amounts of assets into trusts. These assets include not only cash and investments, but also successful on-going businesses. There are legitimate uses of trusts in tax and estate planning, but the IRS commonly sees highly questionable transactions. These transactions promise reduced taxable income, inflated deductions for personal expenses, reduced (even to zero) self-employment taxes, and reduced estate or gift transfer taxes.

These transactions commonly arise when taxpayers are transferring wealth from one generation to another. Questionable trusts rarely deliver the tax benefits promised and are used primarily as a means of avoiding income tax liability and hiding assets from creditors, including the IRS.

IRS personnel continue to see an increase in the improper use of private annuity trusts and foreign trusts to shift income and deduct personal expenses, as well as to avoid estate transfer taxes. As with other arrangements, taxpayers should seek the advice of a trusted professional before entering a trust arrangement.

Abusive Tax Shelters: Captive Insurance

Another abuse involving a legitimate tax structure involves certain small or “micro” captive insurance companies. Tax law allows businesses to create “captive” insurance companies to enable those businesses to protect against certain risks. The insured claims deductions under the tax code for premiums paid for the insurance policies while the premiums end up with the captive insurance company owned by same owners of the insured or family members.

The captive insurance company, in turn, can elect under a separate section of the tax code to be taxed only on the investment income from the pool of premiums, excluding taxable income of up to $1.2 million per year in net written premiums.

In the abusive tax shelters, unscrupulous promoters persuade closely held entities to participate in this scheme by assisting entities to create captive insurance companies onshore or offshore, drafting organizational documents and preparing initial filings to state insurance authorities and the IRS. The promoters assist with creating and “selling” to the entities oftentimes poorly drafted “insurance” binders and policies to cover ordinary business risks or esoteric, implausible risks for exorbitant “premiums,” while maintaining their economical commercial coverage with traditional insurers.

Total amounts of annual premiums often equal the amount of deductions business entities need to reduce income for the year; or, for a wealthy entity, total premiums amount to $1.2 million annually to take full advantage of the Code provision. Underwriting and actuarial substantiation for the insurance premiums paid are either missing or insufficient. The promoters manage the entities’ captive insurance companies year after year for hefty fees, assisting taxpayers unsophisticated in insurance to continue the charade.

New Convictions for Helping Hide Millions in Israeli Offshore Accounts

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On December 19, 2014, a federal jury sitting in Los Angeles convicted two California tax return preparers of one count of conspiracy to defraud the Internal Revenue Service (IRS) and two counts of willfully failing to file a Report of Foreign Bank and Financial Accounts (FBAR) with respect to secret Israeli Offshore Accounts.

Israeli Offshore Accounts: Facts of the Case

According to the second superseding indictment and evidence introduced at trial, David Kalai and Nadav Kalai were principals of United Revenue Service Inc. (URS), a tax preparation business with 12 offices located throughout the United States. David Kalai worked primarily at URS’s former headquarters in Newport Beach, California, and later at URS’s location in Costa Mesa, California. Nadav Kalai, who is David Kalai’s son, worked out of URS’s headquarters in Bethesda, Maryland, as well as the URS locations in Newport Beach and Costa Mesa. David Almog was the branch manager of the New York office of URS and supervised tax return preparers for URS’s East Coast locations.

The second superseding indictment and the evidence introduced at trial established that the co-conspirators prepared false individual income tax returns that did not disclose the clients’ secret Israeli Offshore Accounts nor reported any income earned from these Israeli Offshore Accounts. In order to conceal the clients’ ownership and control of Israeli Offshore Accounts and to conceal the clients’ income from the IRS, the co-conspirators incorporated offshore companies in Belize and elsewhere and helped clients open secret Israeli Offshore Accounts at the Luxembourg locations of two Israeli banks, Bank A and Bank B. Bank A is a large financial institution headquartered in Tel -Aviv, Israel, with branches worldwide. Bank B is a mid-size financial institution, also headquartered in Tel Aviv, with a presence on four continents.

As further proven at trial, the co-conspirators incorporated offshore companies in Belize and elsewhere to act as named account holders on the secret Israeli Offshore Accounts. The co-conspirators then facilitated the transfer of client funds to the secret Israeli Offshore Accounts and prepared and filed tax returns that falsely reported the money sent offshore as a false investment loss or a false business expense. The co-conspirators also failed to disclose the existence of, and the clients’ financial interest in and authority over, the secret Israeli Offshore Accounts and caused the clients to fail to file FBARs with the U.S. Treasury.

The evidence at trial established that David Kalai and Nadav Kalai each failed to file FBARs for calendar years 2008 and 2009 concerning secret Israeli Offshore Accounts. The bank account for Bank A in Luxembourg was held in the name of a nominee corporation in Belize and held over $300,000.

“The Kalais created sham foreign corporate entities and used banks in Luxembourg and Israel as havens for hiding their U.S. clients’ money from the U.S. government,” said Acting Deputy Assistant Attorney General Wszalek. “Today’s guilty verdict sends a clear message that those professionals who facilitate tax evasion through the use of offshore bank accounts will be held accountable for their criminal conduct. The Tax Division will continue its vigorous tax enforcement efforts in prosecuting return preparers, bankers, and other facilitators who assist clients in concealing assets offshore.”

“As the defendants in this case have learned, hiding income and assets offshore is not tax planning; it’s tax fraud,” said Chief Richard Weber IRS-Criminal Investigation. “There is no secret formula that can eliminate an individual’s tax obligations. Today’s verdict reinforces our commitment to every American taxpayer that we will identify and prosecute those who implement off-shore tax schemes designed to evade the payment of taxes.”

Sentencing of the defendants is scheduled for March 16, 2015.

Israeli Offshore Accounts: Obligation to Report Foreign Accounts and Income Including Israeli Offshore Accounts

U.S. citizens, resident aliens and legal permanent residents have an obligation to report to the IRS on Schedule B of the U.S. Individual Income Tax Return, Form 1040, whether they had a financial interest in, or signature authority over, a financial account in a foreign country in a particular year by checking “yes” or “no” in the appropriate box and identifying the country where the account is maintained. They further have an obligation to report all income earned from the foreign financial account on the tax returns. Separately, U.S. citizens, resident aliens and legal permanent residents with a foreign financial interest in, or signatory authority over, a foreign financial account worth more than $10,000 in a particular year must also file an FBAR with the U.S. Treasury disclosing such an account by June 30th of the following year.

Israeli Offshore Accounts: Lessons from the Kalai Case

The Kalai case is pretty much in line with other similar cases where the IRS was able to obtain criminal conviction for failing to file FBARs to disclose foreign accounts, including secret Israeli Offshore Accounts.

The highly negative factors include: evidence of sophisticated planning to conceal the identify of the secret Israeli Offshore Accounts owners; evidence of international concealment of funds (by reporting them as a business loss) that formed the balances of the secret Israeli Offshore Accounts; evidence of intentional failure to report income from the secret Israeli Offshore Accounts; and the education level of Kalai as tax preparers.

What is critically important for US taxpayers with undisclosed secret Israeli Offshore Accounts to remember is that, if they engaged tax preparers to avoid disclosing their Israeli Offshore Accounts or foreign financial accounts in any other country, they are at an even higher risk of exposure. The reason is because these tax preparers are likely to have engaged in similar pattern of criminal behavior with respect to their other clients; when these other clients do their voluntary disclosure, they are very likely to exposure their tax preparers as well.

This is why it is critically important for US taxpayers with undisclosed secret Israeli Offshore Accounts or foreign financial accounts in any other country to explore their voluntary disclosure options as soon possible and before they are precluded by an IRS investigation.

Contact Sherayzen Law Office for Help with Your Undisclosed Foreign Accounts

If you have undisclosed foreign financial accounts and any other foreign assets, contact Sherayzen Law Office for professional legal and tax help. We will thoroughly analyze your current penalty exposure, identify the offshore voluntary disclosure options available to you, prepare all legal documents and tax forms (including amended tax returns) needed in your case, rigorously defend your interests in front of the IRS, and guide you through the entire voluntary disclosure process.

Contact Us Today to Schedule Your Confidential Consultation!

IRS Criminal Investigation Co-Hosts First International Criminal Tax Symposium

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The Internal Revenue Service Criminal Investigation Division (IRS-CI) and Her Majesty’s Revenue & Customs (HMRC) co-hosted a three-day International Criminal Tax Symposium in Washington, D.C. on January 27 – 29, 2015. The symposium focused on combating offshore tax evasion and international financial crimes. It is worth mentioning that delegates from criminal tax and enforcement programs from Australia, Canada, The Netherlands, Norway and New Zealand also attended the symposium.

IRS states that, recognizing the increasing trends in sophisticated tax evasion and other financial crimes crossing international borders, the symposium participants discussed best practices and methods of effective investigations as well as other strategies to combat emerging issues.

“The IRS continues to enhance its international efforts through a number of strategies working with international law enforcement and actively participating in a number of international financial task force groups. We will continue our recent successes in international cases, following the money across the world to bring criminals to justice,” said Richard Weber, Chief, IRS-Criminal Investigation. “Those who believe they can cross international borders to commit financial crimes will find that they have far fewer places to hide.”

“HMRC is committed to tackling tax crimes through international collaboration and ensuring there is no safe haven for the proceeds of crime,” said Richard Summersgill, Director, HMRC Criminal Investigation. “The world is becoming a much smaller place for those who want to hide themselves and their assets behind anonymous corporate structures.”

Focus of the Symposium

The delegates focused on four key areas: combating beneficial ownerships and the use of shell companies, transnational organized crime, combating offshore tax evasion and refund crimes and repayment fraud.

Combating international financial crimes is a top priority for all of the participating countries and each actively pursues offshore tax evaders, promoters and financial institutions involved in hiding income and assets offshore. Currently, many countries coordinate through international and interagency task forces, exchange of information methods, joint investigations and other formal and informal methods of international cooperation. The IRS affirms that the symposium delegates discussed further enhancements to this international collaboration moving forward.

FATCA and Beneficial Ownership Issue

The beneficial ownership problem is one that is probably most difficult to trace for the IRS at this point, because it may not be as easily detectable through FATCA as, for example, individual or partnership ownership of foreign accounts. Therefore, it is not surprising that the symposium emphasized this aspect of international tax enforcement.

Symposium and Non-Compliant Foreign Accounts

This symposium is one more evidence of an ever closer cooperation between countries in terms tackling international tax enforcement. With FATCA being adopted as the global standard for tax enforcement, US owners of non-compliant foreign accounts are in ever-more present danger of discovery.

If the evidence is found that these owners used foreign entities to conceal their beneficial ownership of the foreign accounts, there is a very high likelihood of the IRS pursuing criminal penalties against non-compliant US taxpayers.

This is why it is so important for non-compliant US taxpayers to consider their voluntary disclosure options before it is too late (if the IRS commences an investigation of these accounts, the voluntary disclosure options may be entirely precluded).

Contact Sherayzen Law Office for Experienced Help with Undisclosed Foreign Accounts and Other Assets

If you are a US person with undisclosed foreign accounts, please contact Sherayzen Law Office to secure professional, experienced and creative legal help. Our experienced law firm will thoroughly analyze your case, discuss with you the available voluntary disclosure options, prepare and file your entire voluntary disclosure case (including all legal documents and tax forms), and negotiate the final settlement with the IRS.

Streamlined Domestic Offshore Compliance Process

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In a previous article, I discussed the eligibility requirement with respect to the Streamlined Domestic Offshore Procedures. In this article, I would like to explore the specific filing requirements under the Streamlined Domestic Offshore Procedures.

As a side note, it is important to emphasize that this is just an educational article on the general overview of technical filing requirements. However, this article does not constitute legal advice and omits some very important complexities that may arise in individual cases. This is why I strongly discourage pro se (i.e. self-representation) disclosures under the Streamlined Domestic Offshore Procedures. On the contrary, the decision to engage in the Streamlined Domestic Offshore option should only be handled by an experienced international tax lawyer.

The Streamlined Domestic offshore filings can be organized in the following seven parts. Note that not all of the discussed requirements may apply in some cases and additional documents may be required in other cases.

1. Streamlined Domestic Offshore Procedures: U.S. Tax Returns

Very precise instructions were issued by the IRS with respect to filing U.S. tax returns under the Streamlined Domestic Offshore procedures. For each of the most recent 3 years for which the U.S. tax return due date (or properly applied for extended due date) has passed, the taxpayer must submit Form 1040X together with any of the required information returns (e.g., Forms 3520, 3520-A, 5471, 5472, 8938, 926, and 8621).

The taxpayer should include at the top of the first page of each delinquent or amended tax return and at the top of each information return “Streamlined Domestic Offshore” written in red to indicate that the returns are being submitted under these procedures. The IRS warns that this is critical to ensure that the taxpayer’s returns are processed through Streamlined Domestic Offshore Procedures. My practice is to apply the same stamp to each of the required information returns submitted under the Streamlined Domestic Offshore Procedures, even if these returns are attached to the amended tax returns.

Two important issues must be kept in mind when submitting tax returns under the Streamlined Domestic Offshore Procedures. First, the information returns mentioned above (e.g. Forms 3520, 3520-A, 5471, 5472, 8938, 926, and 8621) should be submitted with the amended U.S. income tax returns even if these information returns would normally not be submitted with the Form 1040 had the taxpayer filed a complete and accurate original return.

Second, the taxpayer may not file delinquent income tax returns (including Form 1040, U.S. Individual Income Tax Return) using Streamlined Domestic Offshore Procedures. This is one of the most critical differences between the Streamlined Domestic Offshore Procedures and Streamlined Foreign Offshore Procedures.

2. Streamlined Domestic Offshore Procedures: Payment of Tax Due

Together with the U.S. tax returns, the taxpayer should submit the payment of all tax due as reflected on the tax returns and all applicable statutory interest with respect to each of the late payment amounts. The taxpayer’s taxpayer identification number must be included on each check. Under the Streamlined Domestic Offshore Procedures, the taxpayer is not required to pay any failure-to-pay penalties and accuracy-related penalties,

3. Streamlined Domestic Offshore Procedures: FBARs

The Streamlined Domestic Offshore Procedures follow the FBAR statute of limitations and require the taxpayer to file delinquent FBARs for each of the most recent 6 years for which the FBAR due date has passed. The FBARs should be filed according to the FBAR instructions and they should include a statement explaining that the FBARs are being filed as part of the Streamlined Filing Compliance Procedures.

All FBARs must be e-filed at FinCen. On the cover page of the electronic form, select “Other” as the reason for filing late. An explanation box will appear. In the explanation box, enter “Streamlined Filing Compliance Procedures.” While not required, it may be beneficial to include a more expanded statement to briefly state the circumstances – it is the job of an international tax attorney to critically look at his client’s case and see if this is the right strategy.

4. Streamlined Domestic Offshore Procedures: Payment of the Miscellaneous Offshore Penalty

In a stark contrast to Streamlined Foreign Offshore Procedures, the Streamlined Domestic Offshore Procedures option requires the participating taxpayers to pay the Title 26 Miscellaneous Offshore Penalty of 5%. The definition of the Title 26 Miscellaneous Offshore Penalty is beyond the scope of this article; however, you can read this article I posted earlier for a more elaborate discussion of this penalty and how it is calculated.

The check for the payment of the Miscellaneous Offshore penalty should be made payable to the “United States Treasury” and the taxpayer’s taxpayer identification number must be included on the check.

5. Streamlined Domestic Offshore Procedures: Certification of Non-Willfulness (IRS Form 14654)

This is the most critical part of the voluntary disclosure package under the Streamlined Domestic Offshore Procedures. The taxpayer must complete and sign Form 14654, “Certification by U.S. Person Residing in the United States for Streamlined Domestic Offshore Procedures”. The taxpayer must submit the original signed Form 14654 to the IRS. Furthermore, he must also attach copies of the statement to each tax return and information return being submitted through Streamlined Domestic Offshore Procedures.

The IRS warns that failure to submit this statement, or submission of an incomplete or otherwise deficient statement, will result in returns being processed in the normal course without the benefit of the favorable terms of the Streamlined Domestic Offshore Procedures.

At this point, the IRS does not currently require the attachment of copies of Form 14654 to FBARs, but this may change in the future.

6. Streamlined Domestic Offshore Procedures: Late Deferral Requests

The taxpayer may also use the Streamlined Domestic Offshore Procedures to make retroactive elections requests. If the taxpayer seeks relief for failure to timely elect deferral of income from certain retirement or savings plans where deferral is permitted by an applicable treaty, he should submit the following items as part of his disclosure package under the Streamlined Domestic Offshore Procedures:

a). A statement requesting an extension of time to make an election to defer income tax and identifying the applicable treaty provision;

b). A dated statement signed by you under penalties of perjury describing: (i) the events that led to the failure to make the election; (ii) the events that led to the discovery of the failure, and (iii) if the taxpayer relied on a professional advisor, the nature of the advisor’s engagement and responsibilities; and

c). For relevant Canadian plans, a Form 8891 for each tax year and each plan and a description of the type of plan covered by the submission.

7. Streamlined Domestic Offshore Procedures: Mailing Address as of January 29, 2015

Once the above-described documents are gathered into one package (together with the payments), this package should be sent in paper format to the following address:

Internal Revenue Service
3651 South I-H 35Stop 6063 AUSC
Attn: Streamlined Domestic Offshore
Austin, TX 78741

This address may only be used for returns filed under Streamlined Offshore Domestic Procedures and may change over time; so an international tax lawyer should verify any changes to the address prior to submission of any documents under the Streamlined Domestic Offshore Procedures.

Contact Sherayzen Law Office for Legal Help with Your Voluntary Disclosure Under Streamlined Domestic Offshore Procedures

If you have undisclosed foreign financial accounts and other assets, please contact Mr. Eugene Sherayzen an experienced tax attorney, owner of Sherayzen Law Office for legal and tax help. Our experienced international tax firm specializes in offshore voluntary disclosures and we can help you.

Contact Us to Schedule Your Confidential Consultation!