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Foreign Accounts

The Department of Justice has embarked on an active pursuit to penalize and tax funds and assets that are held in accounts outside of the United States. At Bucci Law Offices, we understand that facing the Department of Justice and the IRS can be a daunting and seemingly impossible task, but we have saved our clients millions of dollars in taxes, penalties and interest. Our tax attorneys understand the complexities of international tax law, and we have provided professional planning and tax services to our clients since 1996.

During every step of the process, our tax attorneys rigorously defend our clients through oral and written advocacy. If we cannot settle or dismiss the case during administrative proceedings, we then provide the best possible strategy for our clients to litigate their issue(s) in front of the U.S. Tax Court.

Why Should You Contact Bucci Law Offices For A Consultation?

On Aug. 29, 2013, the United States Department of Justice and the Swiss Federal Department of Finance issued a joint statement announcing a program, which is designed to unearth the tax shelters that have evaded the IRS for decades. The Program essentially allows any Swiss bank to admit wrongdoing, pay the appropriate fine and/or penalty without having to fear further prosecution.

Every U.S. taxpayer who is a foreign account holder is subject to fines and penalties, even if tax avoidance was not the principal purpose of holding the accounts. To date, the Department of Justice has received several guilty pleas, guilty verdicts and substantial fines from various institutions. Unfortunately, this is just the tip of the iceberg because the Department of Justice and IRS have shown no signs of slowing down their pursuit against any individual or institution that held funds or assets in foreign accounts.

As of Dec. 31, 2013, over 100 banks have agreed to provide the Department of Justice with the names of its account holders and the details of their activity. Major banks, such as UBS AG, Credit Suisse Group AG, Wegelin Bank, Valiant Bank, Berner Kantonalbank and Vontobel, are among those who have already provided the Department of Justice with the names and details of its account holders. The 194 banks, estimated to remain will then fall into one of the three categories below:

  1. Any bank that has reason to believe it may have committed tax-related offenses or monetary transaction offenses in connection with undeclared U.S. accounts held by the Swiss bank
  2. Any bank that has not committed any tax-related offenses in connection with undeclared U.S. accounts held by the Swiss bank
  3. Any bank that is a "Deemed Compliant Financial Institution" qualified as a "Financial Institution with Local Client Base"

The program defines a U.S. account as "an account which exceeded $50,000 in value at any time during the applicable period, as measured by the account balance on the last day of each month during the applicable period, and as to which indicia exists that a U.S. person or entity has or had a financial or beneficial interest in, ownership of, or signatory authority over the account."

A taxpayer who has foreign bank accounts or assets should not wait to see if he or she can continue to fly beneath the Department of Justice's and the IRS's radars. Our international tax lawyers urge any taxpayer who believes he or she has undisclosed foreign accounts or unreported income to come forward. Let us assess your situation and petition for your acceptance into the Offshore Voluntary Disclosure Program to reduce your overall liability. Contact Bucci Law Offices, or call 954-900-9107. Based out of Miami and Fort Lauderdale, we represent taxpayers worldwide. Call us today to schedule a consultation.