ORANGE COUNTY, Calif. -- IRS CRACKS DOWN ON OVERSEAS TAX EVADERS

Currently the IRS is actively pursuing individuals with overseas Foreign Accounts and income producing properties by allowing them to come clean under the OVDI (Offshore Voluntary Disclosure Initiative). The purpose of the act is for individuals to disclose previously unidentified foreign accounts and become current on their tax liability and FBAR filings.

It looks like the gloves are off though – in order to further complement the OVDI (Offshore Voluntary Disclosure Initiative), The Internal Revenue Service is increasing pressure on not only the people sheltering money overseas (which amounts to a staggering amount of penalties against the non-compliant individuals), but the IRS is also gunning for the institutions facilitating the money caves. The IRS has recently issued ‘John Doe” summonses in its attempts to thwart improper tax diversion accounts overseas. Recent court orders require some of the United States’ largest banks and financial institutions to release information about U.S. account holders who allegedly hid money with banks based in Switzerland and Bermuda to evade taxes, federal prosecutors said on Tuesday.

As provided in Reuters, In two "John Doe" summonses authorized by U.S. district court judges in Manhattan, the five banks must turn over information on taxpayers suspected of hiding money with two foreign banks, Switzerland's Zurcher Kantonalbank (ZKB) and Bermuda's the Bank of N.T. Butterfield & Son Ltd. The five banks targeted are Citibank, Bank of New York Mellon Corp, JPMorgan Chase, Bank of America and the U.S. branch of Britain's HSBC.

The purpose of these John Doe summonses is essentially to uncover the names of individuals who are currently unknown to the IRS, so that the IRS can go after them for penalties, sanctions, and possibly criminal charges. Usually, banks are reluctant to release the name and identities of its high dollar clients, which is why the summonses are required. As provided by Daniel Werfel, the acting Internal Revenue Service commissioner, "These John Doe summonses for correspondent account records show our determination to pursue evaders using offshore accounts even if the person hiding money overseas chooses a bank that has no offices on U.S. soil.”

S. Matthew Golding’s domestic and international law practice emphasizes the representation of clients worldwide in matters involving Tax, Estate Planning, and Probate Law. Matthew’s clients include U.S. and foreign citizens living abroad in countries such as Iraq, Japan, Afghanistan, Indonesia, South Africa, Pakistan, and Korea. Matthew is currently enrolled in one of the nation’s Top Master of Tax Law Programs at the University of Denver in a distance program designed for experienced professionals. He worked his way through school, graduating University of Denver (1996) and Whittier Law School (1999) and earning Dean’s List distinction at both institutions.

Member, State Bar of California, 1999-Present
Member, State Bar of New York, 2004-Present
Enrolled Agent, Federally Licensed Tax Practitioner (Highest credential awarded by the IRS)
Admitted, United States Tax Court
Real Estate Broker, California Department of Real Estate

He is the owner and operator of http://www.GoldingLawyers.com, http://www.GoldingTaxSolutions.com, and http://www.GoldingRealEstateStrategies.com


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