State Bar of California
Super Lawyers

Top Tax Practice Tips and Representation Strategies: Offshore Accounts—Quick Tips

University of Southern California
2012 Tax Institute

Millennium Biltmore Hotel
Los Angeles, California 

January 24, 2012 

©2012 Dennis Brager, Esq.*

Offshore Accounts—Quick Tips

The IRS investigation into taxpayers with unreported foreign bank accounts continues unabated. The IRS has stated that more than 30,000 disclosures of offshore accounts have been made. UBS turned over the names of around 4,500 account holders pursuant to a John Doe summons. Names of some HSBC India clients have been made available to the IRS. Credit Suisse has already begun turning over the names of some of its clients. Press reports indicate that the IRS is in negotiations with the Swiss government and at least 11 Swiss banks. If the negotiations are successful these banks would turn over the names of their U.S. account holders, and avoid criminal prosecution. It appears that banks in other countries including Israel are also under investigation.

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*Dennis Brager, Esq., is a State Bar Certified Tax Specialist in Los Angeles. A former IRS senior trial attorney, Mr. Brager now devotes his efforts exclusively to helping clients resolve their tax problems with the IRS and California State tax agencies. Services include negotiating Tax Debts, Tax Fraud Representation, Tax Litigation, Tax Audit and Appeals Representation,  Tax Preparer Penalty Mitigation, Payroll Tax Audits, and California Sales Tax Problems. He may be reached at 800.380.TAX LITIGATOR.

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