Client Alerts

Memorandum: F.B.A.R. Update

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To Clients and Friends of the Firm:

On May 8th, IRS representatives and members of the private bar whose practice is concentrated on white collar matters participated on a panel addressing the current status of the voluntary disclosure program for unreported foreign financial accounts. The panel was sponsored by The American Bar Association Section of Taxation. The free flow of comments and responses among the participants was enlightening. Here are some of the highlights.

Expect more activity; the offshore voluntary disclosure is a priority

More than 97% of the participants have been accepted into the program. Although only a small fraction of participants have moved into the examination stage, about 225 agents have been trained and assigned to work in the program. Consequently, more activity from the IRS is now expected. This corroborates recent activity in our practice where we have received telephone calls initiating examinations on a daily basis for the last week or ten days.