If you have unreported offshore bank accounts, you may be aware that you can disclose these accounts to the IRS while minimizing your penalties and criminal exposure. However, you may also be inclined to refrain from disclosing these accounts immediately. That said, the question is: Disclose now or later?

As a U.S. taxpayer, you have the right to challenge any IRS tax bill that you believe is either unfair or inaccurate. However, any such challenge will need to comply with strict guidelines and procedures. This is not something that is advisable for the taxpayer to do on their own. Legal representation will be necessary.

Any U.S. taxpayer is expected to comply with IRS rules and regulations, including in situations where a U.S. affiliated person lives abroad. There are strict rules in the United States for taxpayers who have financial accounts outside of this country, even if those taxpayers are living in a foreign jurisdiction and simply have an account in a bank where they live. Depending on the account's value, requirements may include filing an annual Report of Foreign Bank and Financial Account (FBAR). Taxpayers may also be required to disclose foreign assets by filing Form 8938 with their tax returns.

Managing Partner Kevin E. Thorn was recently asked by a DC news source to comment on former Trump campaign chairman Paul Manafort’s trial taking place in a federal court in Alexandria, Virginia.

Swiss banks had a long tradition of providing privacy and providing top quality service. This prompted wealthy individuals and businesses from throughout the world to invest their funds in Swiss banks.  However, in recent years, many Swiss banks have been forced to turn over financial information and account details on foreign investors with Swiss bank accounts.