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By: Lance Wallach
The Internal Revenue Service will extend until October 15th its limited amnesty
program for U.S. taxpayers with undeclared income on foreign accounts, according to
The special voluntary disclosure program was begun in March after UBS AG
turned over the names of more than 250 account holders as part of a criminal
settlement. The IRS said the extension comes after “repeated requests” from tax
professionals who need more time to help taxpayers enter the program. More than
3,000 taxpayers had come forward so far for all of last year. The program has received
undue attention due to a dispute between the U.S. and Swiss governments over the
identities of U.S. taxpayers holding $10 billion in 52,000 secret accounts at UBS. In
August, the Swiss government agreed to identify at least 4,450 more UBS account
holders and possibly many from other accounts.
I have been inundated with calls from people needing help and advise.
Taxpayers are stepping forward due to deadline pressure. Another reason is that
UBS recently sent the first round of letters to some account holders informing them
that their information is about to be revealed. There has been no discernible pattern
as to which customers were selected, ruining the hopes of those who might have
thought they could escape scrutiny because their accounts were too small or were
devoid of potential evidence of intent to evade taxes.
Taxpayers are deciding to confess for many reasons including they want to sleep
at night. Another is that they do not have access to the money anyway. Many of those
accepted into the IRS’s disclosure program will owe back taxes, interest and a special
penalty that will work out to 40% to 60% of the account balance, plus legal and
accounting fees. It is unlikely they will bring criminal charges against anyone who
Those who have been notified that their identity is about to be revealed to the
IRS can appeal release of the information in Swiss courts. U.S. law requires any
taxpayer who does so to notify the Justice Department. Failing to do so will make any
criminal case worse. If you are in this type of situation do something NOW!!.
Lance Wallach, CLU, ChFC, CIMC, speaks and writes extensively about financial
planning, retirement plans, and tax reduction strategies. He is an American Institute
of CPA’s course developer and instructor and has authored numerous best selling
books about abusive tax shelters, IRS crackdowns and attacks and other tax matters.
He speaks at more than 20 national conventions annually and writes for more than 50
national publications. For more information and additional articles on these subjects,
visit www.vebaplan.com, www.taxlibrary.us, lawyer4audits.com or call 516-938-5007.
The information provided herein is not intended as legal, accounting, financial or
any other type of advice for any specific individual or other entity. You should
contact an appropriate professional for any such advice.
Lance Wallach, the National Society of Accountants Speaker of the Year, speaks and
writes extensively about retirement plans, Circular 230 problems and tax reduction
strategies. He speaks at more than 40 conventions annually, writes for over 50
publications and has written numerous best-selling AICPA books, including Avoiding
Circular 230 Malpractice Traps and Common Abusive Business Hot Spots. Contact him
at 516.938.5007 or visit www.vebaplan.com.
The information provided herein is not intended as legal, accounting, financial or any
other type of advice for any specific individual or other entity. You should contact an
appropriate professional for any such advice.
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