Offshore Private Banking Campaign 2019 - IRS Increases Enforcement (Golding & Golding)

Offshore Private Banking Campaign 2019 – IRS Increases Enforcement (Golding & Golding)

Offshore Private Banking Campaign 2019 – IRS Increases Enforcement

The IRS continues to increase enforcement on all things “offshore.” On April 16, 2019, the IRS introduced new International Tax campaigns, and one of the main focuses is Offshore Private Banking Campaign.

Common Questions about Offshore Private Banking Campaign:

What is an Offshore Account?

From the IRS perspective, an Offshore Account is simply an account located outside of the United States. The IRS uses the terms Offshore, Foreign, and International interchangeably.

Are Offshore Accounts Illegal?

No. The mere ownership of an offshore account is not illegal. The illegal part of the offshore account is when a U.S. person tries to hide the account, or keep it a secret from the U.S. government.

What are the Benefits of an Offshore Bank Account?

It used to be the ability to keep the account shrouded in secrecy and away from the U.S. Government. With the introduction of offshore tax enforcement groups, FATCA, J5, and renewed interest in FBAR — those benefits have been overshadowed by U.S. government regulations.

What is the Definition of Private Banking?

Private Banking with respect to offshore banking is usually defined as banking n places such Switzerland, Luxembourg, Panama, Cayman, Bermuda, Bahamas, and more.

Offshore Private Banking Campaign

The IRS recently introduced a new International Tax Compliance campaign, for “Offshore Private Banking”


“U.S. persons are subject to tax on worldwide income from all sources including income generated outside of the United States.


It is not illegal or improper for U.S. taxpayers to own offshore structures, accounts, or assets. However, taxpayers must comply with income tax and information reporting requirements associated with these offshore activities.


The IRS is in possession of records that identify taxpayers with transactions or accounts at offshore private banks.


This campaign addresses tax noncompliance and the information reporting associated with these offshore accounts.


The IRS will initially address tax noncompliance through the examination and soft letter treatment streams. Additional treatment streams may be developed based on feedback received throughout the campaign.”


What if I am Out of Offshore Compliance?

If you are out of offshore compliance, the penalties can be severe. Therefore, you may consider entering the IRS offshore voluntary disclosure/tax amnesty, before it is too late.

Golding & Golding, A PLC

We have successfully represented clients in more than 1000 streamlined and voluntary disclosure submissions nationwide, and in over 70-different countries.

We are the “go-to” firm for other Attorneys, CPAs, Enrolled Agents, Accountants, and Financial Professionals across the globe.