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Offshore Accounts and the New IRS Voluntary Compliance Initiative
The Herman Goldman Memorial Lecture

Wednesday, June 22, 2011 6 PM

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Although the IRS has been increasingly concerned about the growth of offshore tax evasion and the threat posed to tax compliance, the coordinated attack of the IRS and Justice Department over the last three years achieved dramatic and unanticipated advances to breach key secrecy barriers of international tax havens. These efforts led to historic agreements with the Swiss government and perhaps the most successful tax compliance initiative in history – resulting in voluntary disclosures by over 18,000 taxpayers of their secret offshore bank accounts. KEVIN M. DOWNING, Senior Trial Attorney for the Justice Department’s Tax Division, will describe the key developments leading to these dramatic enforcement successes and the US government’s continuing strategy. MARK E. MATTHEWS, of Morgan Lewis and Bockius, LLP and a former senior IRS official, will discuss the operations of the IRS disclosure programs, the penalty structures involved, the most significant issues his clients consider when deciding whether to disclose their accounts, and the recent criticisms of the programs by many tax professionals