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Voluntary Disclosure Matters

Practice Area

Practice Areas

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.

Experience & Expertise
  • Offshore Voluntary Compliance Initiative (2003 OVCI) - closed

  • Offshore Credit Card Program (2003 OCCP) - closed

  • Offshore Voluntary Disclosure Program (2009 OVDP) - closed

  • Offshore Voluntary Disclosure Program (2012 OVDP) - closed

  • Offshore Voluntary Disclosure Program (2014 OVDP)  - closed

  • Updated Voluntary Disclosure Practice (2018) – expired November 2020

  • Internal Revenue Manual Voluntary Disclosure Practice (September 2020)

  • IRS Form 14457 (Voluntary Disclosure Practice Pre-Clearance)

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Friday, May 14, 2021

U.S. Department of Justice for the Southern District of New York filed a criminal information charging Swiss Life Holdings AG and three subsidiaries 


Read the full DOJ Press Release here:

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