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Am Law 100 firm with practices in Business, Digital Assets and Data Management, Intellectual Property, Labor & Employment, Litigation and Tax.

Home | BakerHostetler

Rutkowski joins panel discussion about AI use in marketing

Reid says Congress should broaden (not curtail) nonprofit free speech rules

Antitrust Advocate

State Attorneys General Take a Strong Pro-Enforcement Stance in Comments to Draft Merger Guidelines

Examining the context, impact of Ohio high court tax statute decision

Partner and Co-Chair of Baker Hostetler's nationwide <a href="http://www.bakerlaw.com/taxcontroversylitigation/">tax controversy practice</a>, <a href="/jamesnmastracchio/">Jim Mastracchio</a> commented on the IRS offshore voluntary disclosure program in The New York Times (“Voluntarily Disclose Your Offshore Accounts, or Else”) on August 26, 2011. The New York Times reported that since the IRS initial voluntary disclosure program drew in well over 15,000 undeclared accounts, it made sense for the IRS to offer a second round of disclosure which began in February and ends on September 9. According to the article, however, people may not be as persuaded to disclose in this round: “the penalties are steeper up to 25 percent of the value of the assets and they’re assessed on the highest value of those assets over the last eight years,” a considerable change from the last voluntary disclosure program. Mastracchio commented on the penalty structure of the current program and gave examples of taxpayers who have decided to opt-out of the 2009 program. “The program works for people who were willful, who structured their transactions, who hid the existence of the accounts or knew about the rules and didn’t file they shouldn’t opt out because the willful penalties are quite severe,” said Mastracchio. “Not everyone is in that bucket.”

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Tax Controversy and Litigation

Mastracchio Comments on IRS Offshore Voluntary Disclosure Program in The New York Times

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