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Abusive Offshore Tax Avoidance Schemes

You have come to the right place to report tax fraud or tax evasion and apply for an IRS Whistleblower Award of 15% to 30% of the amount collected based upon the information you provide. As former IRS attorneys, we concentrate in the IRS Whistleblower Reward Program and have comprehensive knowledge of offshore tax fraud, abusive offshore tax avoidance schemes, abusive tax shelters, and Bitcoin tax evasion utilized by tax shelter promoters, offshore corporations, LLCs, LLPs, partnerships, trusts, individuals, banks, investment companies, international business companies, insurance companies, and others. Our IRS Whistleblower attorneys are eager to put their tax legal skills and experience to work to maximize IRS Rewards for our clients. We represent clients from across the world.

Citizens and residents of the United States are taxed on their worldwide income. However, because of the lack of communications of property held offshore to that of the IRS, many U.S. taxpayers have taken advantage of their abilities to hide both income and assets offshore. Sometimes these are done through legal means (transfer pricing schemes) and sometimes through illegal means (abusive offshore tax avoidance schemes). The Panama Papers has shed light on some of these practices.

Significantly, a Tax Whistleblower may qualify for the IRS Whistleblower Program by providing information as to either legal or illegal means. The tax whistleblower program applies to any underpayment of tax for which you provide information.

Every instance of tax fraud is harmful to every person in the United States. For example, when it comes to large scale transfer pricing schemes involving tax fraud such massive tax avoidance is hurtful to the nation's financial well-being. The money lost by the taxpayers of the U.S. from offshore tax fraud is estimated to be in the tens of billions. Basically taxpayers pay extra so that abusive offshore entities and their stakeholders can make more profit.

Congress and the IRS have taken action. To help prevent the use of offshore entities for tax evasion or deferral, Congress has enacted several specific provisions in the Internal Revenue Code. Some provisions trigger recognition of gains that would otherwise be deferred. Others deny deferral of tax on income moved offshore.

The Foreign Account Tax Compliance Act (FATCA) was enacted into law on March 18, 2010 and is intended to increase compliance for U.S. persons to report income from offshore accounts.

Though promoters of offshore tax schemes often advance technical arguments, which purport to show that their scheme is legal, the intent of Congress remains clear. U.S. taxpayers are not to be allowed to evade taxes by shifting their own liability to some foreign entity.

Since Swiss bank Whistleblower Brad Birkenfeld contacted the IRS and the Department of Justice and provided “specific and creditable” information as to the billions of dollars that U.S. taxpayers kept in overseas bank accounts in 2007, Congress as well as the IRS have been focused on the enforcement of the tax laws with respect to these individuals that use legal and illegal means of not reporting their offshore activities.

As of December 31, 2011, the IRS Offshore Programs have produced $4.4 billion. On January 9, 2012, the Internal Revenue Service reopened the Offshore Voluntary Disclosure Program (OVDP) to help people hiding offshore accounts get current with their taxes. This is now the third of three recent “amnesty” programs for those taxpayers with accounts offshore to come forward and self report.

The IRS reopened OVDP following continued strong interest from taxpayers and tax practitioners after the closure of the 2011 and 2009 programs. The third offshore program comes as the IRS continues working on a wide range of international tax issues and follows ongoing efforts with the Justice Department to pursue criminal prosecution of international tax evasion. This program will be open for an indefinite period until otherwise announced.

IRS Commissioner Doug Shulman stated:

Our focus on offshore tax evasion continues to produce strong, substantial results for the nation’s taxpayers. We have billions of dollars in hand from our previous efforts, and we have more people wanting to come in and get right with the government. This new program makes good sense for taxpayers still hiding assets overseas and for the nation’s tax system.

As we’ve said all along, people need to come in and get right with us before we find you. We are following more leads and the risk for people who do not come in continues to increase.

Today, the IRS will vigorously pursue tax cheats around the world, no matter how remote or secret the location. The IRS works with other governments to obtain the information. Wealthy Americans who have hidden their money offshore will find themselves in a jam.

If you have knowledge of an Abusive Offshore Tax Avoidance Scheme, are not sure whether the offshore entity or activity is part of a tax scheme, or would like to know if the information you possess falls within the IRS Whistleblower Program, do not hesitate to contact us for a free confidential evaluation. As former IRS attorneys, we are intensely aware of the desire for IRS Whistleblower confidentiality and IRS Whistleblower protection. So, do not worry about disclosures that are protected under the attorney-client privilege. This is all we do. We enjoy our work and look forward to hearing from you.

IRS examples of of entities and schemes being used in Abusive Offshore Tax Schemes:

Foreign trusts
Foreign corporations
Foreign (offshore) partnerships,
LLCs and LLPs
International Business Companies (IBCs)
Offshore private annuities
Private banking (U.S. and offshore)
Personal investment companies
Captive insurance companies
Offshore bank accounts and credit cards
Related-party loans

Read about Filing A Claim In The IRS Whistleblower Program .

IRS Headquarters, Washington, DC

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