Voluntary Disclosure Matters
The Firm has long been active in matters involving taxpayer voluntary disclosures and was heavily involved with the IRS introduction of the first formal Offshore Voluntary Disclosure Program (OVDP 2009), a settlement program that encouraged U.S. taxpayers to voluntarily disclose previously undeclared foreign accounts. As the Program continued through to 2018 with the introduction of the Updated Voluntary Disclosure Practice, the Tax Group has advised countless HNW individuals, families, and financial institutions on the disclosure of hundreds of previously undeclared foreign financial accounts, trusts, foundations and entities.
The trend of global compliance and reporting has spread around the world with the introduction of FATCA and CRS global reporting programs. The Firm is therefore pleased to continue our involvement with ongoing compliance matters for individual clients, as well as through the development and delivery of educational content to global private banks, asset advisors, trust companies and professional firms.
Our roles as attorneys are to identify and define the client’s requirements and situation, assess potential criminal exposure, evaluate taxpayer motivations in examining and reconciling the issue of “willfulness”, recognize and manage the emotional concerns clients may have in addressing their past filing issues, efficiently collect and evaluate the underlying tax and financial background information involving the issue at hand and craft strategies based on the underlying facts of the cases to minimize income tax and penalty exposure for the client.
The Tax Group applies decades of knowledge and experience to assess available voluntary disclosure options and works to minimize the potential impact of the voluntary disclosure on the taxpayer, including the careful and accurate analysis of unreported income and interest, and diligent work in minimizing underreporting penalties.