Taxpayers May Need Tax Attorney for Voluntary Disclosure Says William D. Hartsock, Esq.

Aug 16, 2011, 06:00 ET from

SAN DIEGO, Aug. 16, 2011 /PRNewswire/ -- Taxpayers all over the country are scrambling to take advantage of the 2011 Offshore Voluntary Disclosure Initiative (OVDI), the IRS' attempt to bring U.S. taxpayers with offshore accounts into compliance which ends August 31, 2011. But San Diego tax attorney William D. Hartsock, Esq. is warning taxpayers to find representation first before filing their overdue FBAR.

"It is currently the practice of the IRS that Voluntary Disclosure is considered along with all other factors in the investigation in determining whether criminal prosecution will be recommended. However, this Voluntary Disclosure practice does not guarantee any rights for taxpayers, it's provided solely for guidance to IRS personnel," said Mr. Hartsock.

The IRS recently announced they have hired 800 new employees to investigate U.S. individuals and business taxpayers with foreign-sourced income and accounts. Additionally, the IRS has obtained information on banks in 70 countries that may have assisted U.S. taxpayers in hiding assets and income and Liechtenstein and Switzerland have agreed to enter into Tax Information Exchange Agreements.

The civil liabilities for not filing an FBAR potentially include fines of the greater of $100,000 or 50% of the amount in the account at the time of violation for each Willful Failure to File. Possible criminal charges related to tax returns potentially include 10 years of prison and a fine up to $500,000 for failure to file an FBAR or the filing of a false FBAR.

"Given the enormity of the civil and criminal penalties for those who are found to be out of compliance with FBAR regulations through an international tax audit, the Voluntary Disclosure Practice is an appealing option," said Mr. Hartsock. "It is critical that a taxpayer who wishes to investigate the Voluntary Disclosure practice seek the expertise of a knowledgeable tax attorney to consult and guide them through the process of making a Voluntary Disclosure that will be in the taxpayer's best interest, however."

For more information on the 2011 Offshore Voluntary Disclosure Initiative (OVDI), or to schedule a no-obligation consultation, call 858-481-4844, or visit today.

Full press release located here:


William D. Hartsock, Esq. is a Certified Tax Law Specialist and international tax attorney specializing in legal counsel for individuals and businesses in need of federal, state and international tax audit assistance.