On the heels of the 100,000 names that were leaked from HSBC, there are 4,183 clients that are United States citizens. With this list the Department of Justice could cross-match these names to the results of the John Doe Summons issued in December 2014(see John Does Order) to determine a list of United States taxpayers that may be evading tax. The IRS has identified companies, like Soverign LTD, that have utilized offshore entities and business merchant accounts to provide an undetectable transfer of funds (see John Does Declaration).
Any taxpayers that could be on these lists and are either non-compliant with their offshore reporting obligations, or have actively participated in the offshore schemes listed above in the John Does Declaration, should immediately seek assistance of an experienced Federally Authorized Tax Practitioner. Compliance paths include the Offshore Voluntary Disclosure Program, Streamline Filing Compliance Procedure and Delinquent FBAR/Informational Return or Report Programs.
About Five Stone Tax Advisers
Five Stone Tax Advisers has years of experience negotiating directly with the IRS to get the best possible outcome for you. Our International Tax Advisory and Compliance unit has a team of tax attorneys, certified public accountants and enrolled agents that form a single sourced point of contact that will provide services for all the legal, compliance and financial reconstruction aspects of offshore account cases.