The Offshore Tax Dilemma

Recent efforts of the IRS to increase tax collections has led to a reinforced breakdown on individuals and entities that are using international entities as off-shore tax shelters – who ultimately use these off-shore entities astax deductible undertakings. In fact, a recent tax-shelter court case was won by the IRS, adding to its list of won tax-shelter cases where it argues that the purchases of distressed assets/debts from off-shore companies to obtain tax deductions from losses lack ‘economic substance’ – meaning that these off-shore acquisitions were purchased solely to garner tax cuts.

Many more offshore holdings of individuals and institutions are being looked into by the IRS; if you have any foreign assets, then it might be best to check out if you’ve already filed out the IRS offshore voluntary disclosureto make sure that you comply with IRS regulations, and avert future problems with civil penalties and criminal prosecution. The IRS voluntary disclosure program was initiated by the IRS as a sort of amnesty initiative to non-compliant stakeholders in its increased expansion of its enforcement efforts. However, if the IRS had already initiated a civil examination, whether or not that examination involved offshore holdings and entities, then you are not eligible for the voluntary disclosure program.

Regardless of your situation with your taxes and holdings, it’s best to consult with anIRS attorneywith any concerns regarding the IRS, your tax filings and your offshore holdings. They can also provide you with counsel regarding other, more routing matters regarding your personal or company taxes.