If You Have or Had Money Overseas You Better File for Amnesty ASAP
According to various reports the IRS is investigating the Israeli banks Bank Leumi, Bank Hapoalim and Mizrahi Tefahot Bank for conspiring with individuals to enter into a loan scheme intended to evade taxes on funds brought to the U.S. from undisclosed foreign bank accounts.
The focus on the banks themselves is a notable departure from similar investigations in the past. In prior investigations, the bank or bankers had a passive relationship, whereas Bank Leumi allegedly took an active role in setting up the scheme to evade taxes.
Bank Leumi has sent letters to various account holders suggesting clients enter into the IRS voluntary disclosure program otherwise known as the Offshore Voluntary Disclosure Program/Initiative (OVDP or OVDI).
To try to reduce the fines we suggest that you then opt out and take your case to the IRS appeals division. Our former IRS appeals officer has lots of experience in this. He was also a manager in the IRS international division. With large fines at stake you probably want the best.
Disclaimer: While every effort has been made to ensure the accuracy of this publication, it is not intended to provide legal advice as individual situations will differ and should be discussed with an expert and/or lawyer.For specific technical or legal advice on the information provided and related topics, please contact the author.