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Caplin & Drysdale | Attorneys
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Tax Controversies
Navigating Criminal Tax Investigations, Sensitive Civil Audits and Voluntary Disclosures Arising Out of Undeclared Offshore Accounts

Caplin & Drysdale has earned a national reputation for handling criminal tax investigations and sensitive civil audits arising from IRS and Department of Justice investigations involving UBS, HSBC and other banks. Federal agencies continue to focus substantial enforcement resources aimed at US taxpayers who may have failed to declare and report income on foreign bank accounts. Caplin & Drysdale attorneys can assist any such taxpayers, relying on the firm's extensive tax and criminal defense experience.

At present, the firm has advised many corporations and individuals worldwide in matters involving the failure to report foreign accounts, the filing of false or incomplete tax returns, unfiled FBAR forms, unreported trust, foundation or corporate structures, problematic estate and gift tax matters arising from undeclared assets, and the failure to file tax returns over an extended period of time. We also advise bankers, financial advisors, lawyers and other persons who may be involved in this growing area of tax enforcement.

The firm also has a robust practice in the area of voluntary disclosures resulting from undeclared offshore accounts. It currently handles over 400 voluntary disclosure matters on behalf of clients with undeclared accounts at UBS, HSBC, Julius Baer and other financial institutions located throughout the world.

For assistance, please contact one of our attorneys: Niles A. Elber, James N. Mastracchio, Scott D. Michel, Cono R. Namorato, Michael G. Pfeifer, Christopher S. Rizek, H. David Rosenbloom and Richard E. Timbie.

For more information on the latest developments, please visit the following links:

Caplin & Drysdale Attorneys in the Media on IRS Voluntary Disclosures

For a comprehensive list of Caplin & Drysdale’s mentions in the media on voluntary disclosures, please click here.

Relevant Press Releases

Relevant Articles

Representative Engagements

We have handled audits, investigations and voluntary disclosures involving undeclared foreign bank accounts in a wide range of circumstances.

* Handled all types of cases in various stages under the IRS settlement initiative.

* Advised and assisted many American taxpayers and their families in completing voluntary disclosures regarding previously undeclared foreign assets, including appropriate foreign bank account reports and repatriation of assets.

* Represented major corporations that had been paying selected employees through offshore accounts or otherwise “off the books,” and successfully guided the companies through the voluntary disclosure process.

* Advised numerous U.S. taxpayers on the proper procedure for making a voluntary disclosure in order to avoid criminal prosecution in situations where they had omitted income or inflated deductions on their prior returns.

* Advised a variety of taxpayers who, for whatever reason, had failed to file tax returns for a period of time and then wished to correct their prior omissions and avoid the worry of being discovered by the IRS.

* Helped taxpayers avoid criminal prosecution when the IRS has commenced an examination of a taxpayer's returns but has yet to discover what the taxpayer knows to have been serious prior inaccuracies or omissions



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