In 2007, the Internal Revenue Service’s efforts to clamp down on offshore tax-avoidance schemes received a boost (and holders of undisclosed offshore accounts received a shock) when Bradley Birkenfeld, a UBS banker, agreed to cooperate with the government. The Birkenfeld disclosures breathed new life into the government’s pursuit of offshore accounts, which reportedly result in a “more than $40 billion-a-year drain on federal coffers.”1
In addition to pursuing criminal charges against offshore accountholders whose names have been disclosed, on March 23, 2009, the IRS sought to encourage accountholders to “come clean” by announcing a reduced penalty structure for taxpayers who availed themselves of its longstanding voluntary disclosure practice.
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