The U.S. government has been aggressively collecting information on U.S. taxpayers and their offshore financial institutions using a diverse assortment of weapons in its arsenal. The government’s stated objective has been to go after U.S. accountholders and all entities and individuals, whether foreign or domestic, who may have assisted criminal conduct. With the recent revelation of the so-called “Panama Papers,” the government may have been handed the means to target not just the accountholders and their offshore banks, but a greater number of the professionals around the world who often link them.

Offshore Accounts

The recently leaked 11.5 million documents from the Panama-based law firm Mossack Fonseca & Co., popularly known as the “Panama Papers,” reportedly will present the U.S. authorities with a vast amount of new information on offshore accounts and their underlying beneficial owners, a number of whom are allegedly current and former world leaders, politicians, celebrities, and parties appearing on the U.S. sanctions blacklist. Aside from unmasking many potentially undeclared U.S. persons (U.S. persons who may have failed to properly disclose their foreign accounts to the IRS), these documents also purportedly expose other parties involved in opening and maintaining their offshore accounts, many of which are said to have been the nominal customers of Mossack Fonseca.1

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