If you find yourself among one of the many thousands of individuals seeking to now investigate whether this IRS amnesty can apply successfully to you, please contact us, time is quickly running out. Please remember that the Amnesty consists of your declaration under penalty of perjury. This declaration is all encompassing and painfully thorough in your declaration of your knowledge, people you contacted, people who may have advised you and/or helped you set up these foreign bank accounts. Also, this letter declaration is not sent to the IRS or the U.S. Treasury! This declaration signed by you under the federal laws of perjury is sent to Criminal Investigation Division of the Internal Revenue Service and within your declaration will be, but not limited to, your disclosure to the Criminal Investigation Division the following:
- Your Full Name
- Your Social Security Number
- Your Date of Birth
- Your Current Address
- Passport Number and Country of Issue
- Current Occupation
- Complete and Comprehensive Explanation for Your Failure to File the FBAR and also Explain the Source of these Funds.
- Disclose if you or any related entities are currently under audit or criminal investigation by the Internal Revenue Service or any other law enforcement authority.
- Has the IRS notified you that it intends to commence an examination or investigation?
- Are you under criminal investigation by any law enforcement authority, if so explain in detail.
- Do you believe that the IRS has obtained information concerning your tax liability, if so explain.
- Estimate the annual range of the highest aggregate value of your offshore accounts/assets.
- For accounts or assets where you have control or are a beneficial owner of the account or asset, list any and all financial institutions and the country where the institution is located. For accounts, please also list the dates the accounts were opened and/or closed. Provide your point of contact at each financial institution.
- Explain the purpose for establishing the offshore account or assets. For example: Holocaust Compensation or Restitution; inherited account; account established prior to World War II, etc.; if tax non-compliance – explain.
- List each person or entity affiliated with the account, their formal structure (i.e., if a corporation, foundation, or trust), and the nature of their relationship to the account (i.e. owner, power of attorney, parent entity of corporate account holder, etc.).
- Explain all face-to-face meetings, and any other communications you had regarding the accounts or assets with the financial institution(s). Also include face-to-face meetings or communications regarding the accounts or assets with independent advisors/investment managers not from the financial institution(s) where the funds are held. Provide the names, locations and dates of these meetings and/or communications.
- Certify that you are willing to continue to cooperate with the Internal Revenue Service, including in assessing my income tax liabilities and making good faith arrangements to pay all taxes, interest, and penalties associated with this voluntary disclosure.
- The Criminal Investigation Division will also then reserves its right to make further contacts with the taxpayer to clarify his/her submission.
- Even if you provide all of the potentially damning information requested in the above 18 items, if the Criminal Investigation Division, subjectively, believes that you are not being open, honest and forthright in all of your answers, documents and answers, the CID will withdraw the Amnesty and commence criminal prosecution. Remember that CID is not concerned with collection of taxes, primarily; they are interested in your incarceration.