IRS Offshore Voluntary Compliance Program Questions

The information below includes questions that IRS Criminal Investigation special agents have asked some taxpayers participating in the IRS Offshore Voluntary Compliance program.


Practitioners might want to document the facts as fully as possible in a detailed summary when submitting under the program. Those considering the Offshore Voluntary Compliance program should consider working with legal counsel in a Kovel arrangement, so that the CPA’s work is shielded by the attorney-client privilege.

  1. What prompted the taxpayers to go into the voluntary disclosure program?
  2. Where are the funds held?
  3. What is the total amount of funds?
  4. Do you have bank records?
  5. What was the initial source of the funds?
  6. Who assisted the taxpayer in opening the bank account?
  7. Who told the taxpayer about the bank account?
  8. Is there a trust involved?
  9. How did the taxpayer deposit money into the account?
  10. How did the taxpayer withdraw money from the account?
  11. Are there any credit or debit cards associated with the accounts?
  12. How did the taxpayer correspond with the bank regarding the account?
  13. Who is the current bank contact?
  14. Did the taxpayer ever meet face to face with the banker?
  15. Did the taxpayer travel outside the U.S. to conduct banking activities?
  16. Where were the bank statements sent?
  17. Who has access to the accounts?
  18. Who prepared the tax returns?
  19. Have you prepared amended tax returns?
  20. Were the returns filed on time?
  21. Did the taxpayers know about the issues discussed today?
  22. Did the taxpayer file FBARs with regard to this account? If not, why not?
  23. If the account was inherited, when did the taxpayer take possession of the account?
  24. Did the account trade in U.S. securities?
  25. Did the taxpayers actively trade securities in the account?
  26. Did the taxpayer file foreign returns?
  27. Does the taxpayer have any direct or indirect control over any foreign entities?
  28. Did the taxpayer file returns with regard to the foreign entities?
  29. This question is specifically directed at UBS AG account holders:  Has the taxpayer been notified that the U.S. requested information pertaining to the taxpayer’s UBS bank account?
  30. In which countries does the taxpayer have foreign accounts?



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