Avoiding Criminal Tax Prosecution of the Client with Foreign Accounts

Your client Jane Doe, the distraught business executive who hopes you can assist her in avoiding a criminal tax prosecution arising from her offshore bank accounts, calls you to inquire about the status of her case. While vacationing in the Caribbean several years ago, she opened accounts for herself and her company at a bank located on Grand Cayman Island. The bank issued her credit and debit cards linked to the offshore accounts, thereby enabling her convenient access to her offshore funds from the United States. In recent years, Jane's personal income tax returns, as well as those of her company, have failed to disclose the offshore accounts or to report the interest earned on them. Nor did she or her company file the required forms reporting those foreign financial accounts. Although Jane had not received any contact from the Internal Revenue Service prior to her engaging your services, she had heard news reports that the IRS had been gathering information about thousands of U.S. taxpayers with credit and debit cards issued by banks in the Caribbean, and she had feared that it was just a matter of time before the IRS would come calling.