Taxpayers with Undisclosed Foreign Accounts

Persons with undisclosed foreign accounts should be aware of the whistleblower program and corresponding awards. If a taxpayer worked with a facilitator or representative in a foreign jurisdiction, that individual may choose to open a whistleblower case if they know the facts and circumstances of another taxpayer’s case with regard to failure to report foreign financial accounts. This is in conjunction with the Department of Justice John Doe Summons procedures, FATCA exchange of information reporting and disclosure of names by banks (recently see Bank Leumi). Finally, Carl Levin’s senate report from early 2014 indicates that the DOJ will investigate the IRS Qualified Intermediary Program from which 7000 foreign banks participate.