OFFSHORE VOLUNTARY DISCLOSURE DEAL OFFERED BY IRS  (UBS, Credit Suisse, HSBC, LGT)

On November 17, 2009, the Annex providing the criteria for selecting which UBS accounts may be turned over to the U.S. was disclosed to the public.  The wording of the Annex is very precise and it may or may not apply to your account.  You should not rely upon the summaries of the Annex reported by the press.  If you have a UBS account, you should immediately seek the advice of an Offshore Voluntary Disclosure Attorney.     

The press is reporting that the first 400 American clients of UBS will be selected for disclosure by the end of the week (by November 20, 2009).  Time is of the essence if you want to make a Voluntary Disclosure. 

The IRS "Amnesty Program" officially expired on October 15, 2009.  However, it remains to be seen how the IRS will handle new disclosure cases submitted after the October 15, 2009 deadline.    

The IRS has indicated that it is back to business as usual and that new voluntary disclosure cases will processed on a case by case basis under the penalty framework in place prior to the implementation of the Amnesty Program. 

Despite IRS assertions that the Amnesty Program has expired, I suspect that the Amnesty Program penalty framework may un-officially remain in existence.  Why?  Consider the following:  (1) the IRS received many more disclosure cases than it ever anticipated; (2)  The IRS does not have adequate resources to deal with the cases on a case by case basis in a manner which still treats taxpayers equally; (3) The IRS needs to use a streamlined process in order to handle the volume of cases it has now; and, (4) The IRS is most certainly expecting new cases when the DOJ goes after the next bank.    

Regardless of your situation, you must keep in mind that every case is different and you should seek the advice of counsel to get a better understanding of your options.  To schedule a consultation, call 305-576-4242. 

For the latest news on the UBS Offshore Accounts CLICK HERE 

We understand that disclosing your offshore account can be a very scary proposition.  We can help you understand the process and make an informed decision regarding your situation.   For an intial consultation, call 305-576-4242.

Our Firm is currently representing a large number of clients in the Offshore Voluntary Disclosure Program offered on March 26, 2009.  We have also successfully represented numerous clients in two prior offshore disclosure initiatives offered by the IRS (OVCI in 2003 & LCCI 2003 - 2009).  In all of our pior offshore voluntary disclosure cases, we have found the IRS to be honorable and respectful of our clients rights.  More importantly, all of our offshore disclosure clients received the deal that was offered by the IRS.  In some instances, we were even able to negotiate better terms for our clients.   

If you have received a letter from UBS advising that your account information may be turned over to the U.S. Government, you may still have time to make a Voluntary Disclosure.  For an intial consultation, call 305-576-4242.

We can represent you even if you live outside of Florida.  We have found that technology and our willingness to travel solves most geographical issues. 

The best way to predict the future is to understand what has happened in the past.  We understand what has happened in the past.   Let us help you with the future.   We have the offshore disclosure experience you need to protect yourself and your family.  Call our office for an initial consultation at 305-576-4242.

For the latest news on the UBS Offshore Accounts CLICK HERE