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Law360 reported on June 18 that resident U.S. taxpayers can use streamlined procedures to participate in the IRS’s offshore voluntary disclosure program if they did not intentionally fail to report the accounts to the IRS. Law360’s article, “IRS Offers Penalty Relief For Some Offshore Account Holders,” noted, “Importantly, the IRS is also increasing the penalty it will lob against taxpayers if they maintain accounts in banks that are under investigation by the agency or U.S. Department of Justice and fail to submit an OVDP preclearance request before news of the investigation becomes public.” In the article, as well as a June 19 article entitled, “Attorneys Face Headaches With IRS Offshore Penalty Update,” Partner <a href="http://www.bakerlaw.com/JamesNMastracchio">James Mastracchio</a> warned that the streamlined program does not offer protection from criminal investigation and told Law360, “Our job as practitioners is to make sure our clients are truly nonwillful and there are no facts that will indicate otherwise. I think they're really putting the onus on us, because once clients use the streamline option, they're barred from OVDP.” <a href="http://www.law360.com/articles/549530">Read the June 18 article</a>.  <a href="http://www.law360.com/articles/549833">Read the June 19 article</a>.

James Mastracchio Discusses New Offshore Voluntary Disclosure Rules with Law360

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