Posted tagged ‘voluntary disclosure’

Taxes Overseas? Fess up without going to jail

March 3, 2011

NEW YORK — Tax payers with money offshore have until the end of August to fess up if they want Uncle Sam to take it easy on them.

The IRS announced on Tuesday that it would give taxpayers a reduction in penalties — and no jail time — if they fess up to any undisclosed overseas accounts by Aug. 31.

“This new effort gives those hiding money in foreign accounts a tough, fair way to resolve their tax problems once and for all,” said IRS Commissioner Doug Shulman in a prepared statement. “And it gives people a chance to come in before we find them.”

Tax payers will face a penalty of up to 25% of the highest annual account balance going back to 2003, though some taxpayers will be able to receive a penalty of as little as 5% depending on the size of the account.

The program also requires tax payers to fork over back taxes, interest and late charges for up to eight years.

IRS: Itemizers can file on Feb. 14

This is the IRS’s second voluntary attempt at this program. In 2009 it reeled in 15,000 taxpayers with undisclosed overseas accounts at banks in more than 60 countries.

Penalties under the new initiative are higher than they were during the 2009 program so that people who waited to fess up aren’t rewarded. However, Schulman said that as the IRS continues to invest more resources in cracking down on these illegal offshore accounts, this is the time to come forward.

“The situation will just get worse in the months ahead for those hiding assets and income offshore,” he said. “This new disclosure initiative is the last, best chance for people to get back into the system.” 

revised from CNN Money Online

Tax Havens’ Days Are Numbered

May 5, 2010

Robert Olsen, 05.03.10

The era of banking secrecy may be coming to an end.

HONG KONG — As Democrats and Republicans haggle over the details of financial reform in the Senate, a new tax law is quietly approaching that will force all overseas banks to reveal the overseas holdings of American account holders.

“I don’t think a lot of people have paid attention to this,” said Scott D. Michel, president of Caplin & Drysdale law firm.

“The whole purpose of this is to put American account holders around the world in a position where they can have no safe haven in any bank that wants to offer U.S. investments to any of its clientele,” he added.

American citizens are required to report all of their worldwide income every year when filing their tax returns. As a part of that process, they are also required to disclose any offshore bank accounts they may have or hold signature authority over.

If an individual falsifies his or her tax claim by concealing their income in offshore accounts, banking secrecy laws in countries like Switzerland have in the past helped to keep that income hidden by making it a crime for the banks and their employees to disclose information about clients.

U.S. lawmakers designed the Foreign Account Tax Compliance Act (FACTA) to “force foreign financial institutions, foreign trusts, and foreign corporations to provide information” on undisclosed assets held by Americans after Dec. 31, 2012. If they fail to do so, the Internal Revenue Service (IRS) can hit the banks with 30% withholding on all income originating from the U.S.

The full details of FACTA have yet to be ironed out between the U.S. Treasury and the IRS, but one of its requirements will include a document for new account holders to sign that waives whatever rights they may have under local banking secrecy laws.

The U.S. estimates that it will raise an additional $8.5 billion in tax revenue over the next 10 years by forcing Americans to disclose income they are hiding from tax collectors.

Spurred by rising fiscal deficits, the United States and other members of the Organization for Economic Cooperation and Development (OECD), particularly Germany and France, have been using a variety of methods to clamp down on tax cheats, tax havens and overseas financial centers.

The most high profile of these were the UBS ( UBS – news – people ) AG case and the OECD’s attempt to name and shame those countries that fail to comply with internationally agreed standards.

Tax havens are usually characterized by extremely low tax rates, strong banking secrecy laws and flexible regulations in terms of licensing, incorporation and supervision. So-called shell companies, trusts and other legal entities are often used to shield assets from overseas authorities.

The OECD had initially singled out 47 jurisdictions that included the likes of Hong Kong, Macau, the Philippines and Malaysia, but hasty commitments to improve transparency along with some backroom deal-making led to all four being removed from the blacklist.

The U.S. tax authorities, however, have recently introduced another far more effective means of collecting information on tax evaders: They pay informers for it.

The IRS Whistleblower Office can pay anywhere between 15% and 30% of the taxes, penalties and interest collected for cases valued at $2 million or more. (See: “Tax Informants Are On The Loose”)

The IRS has yet to make any payments under the new scheme, but that hasn’t dissuaded people like Bradley C. Birkenfeld from trying. Formerly an employee of Switzerland’s largest bank UBS, Birkenfeld was sentenced to 40 months in jail for helping billionaire California real estate developer Igor M. Olenicoff hide $200 million offshore. (See: “April 15 Plea: Pardon Tax Whistleblower”) Motivated in part by the possibility of a reward, Birkenfeld provided evidence to U.S. tax authorities detailing how the secretive Swiss bank helped wealthy Americans hide money offshore.

As a result, UBS was forced to admit wrongdoing, pay a fine of $780 million and to turn over data on as many as 4,450 UBS accounts to the Swiss government, which will pass the information to the U.S.

A number of banks from some of Europe’s best-known tax havens are facing similar investigations. Germany launched over 1,000 tax evasion probes against clients of Credit Suisse ( CS – news – people ) last month. In December the French authorities said that it had the details of 24,000 Swiss bank accounts provided by a former HSBC ( HBC – news – people ) employee.

Fearing the possibility of heavy fines and prosecution, many tax evaders from the U.S., Germany and France have come forward to report their assets.

Michel believes the disclosure of banking secrets will continue to grow. “When you combine the whistleblower regime with the template that the [U.S.] government used in the UBS case, with the information they’re getting with all these voluntary disclosure cases and now FACTA, I think the era of bank secrecy is fairly rapidly eroding in front of our eyes,” he said

Related articles:

Foreign Investment’s New Landscape

CPAs Provide Expertise for Transfer Pricing Analyses

April 28, 2010

MAY 2010

Transfer pricing, the process by which multinational companies set arm’s-length prices for cross-border transactions within a corporate group, is complex and consistently ranks as the No. 1 international tax issue facing multinational companies, according to Ernst & Young’s 2009 Global transfer pricing survey. To avoid penalties and potential interest, most tax authorities require taxpayers to prepare annual transfer pricing reports when they file tax returns.

During its infancy, transfer pricing was dominated by economists. However, as global transfer pricing regulations developed, international examiners gained experience and financial accounting standards evolved. Consequently, companies now need experienced tax accountants not only to validate the reliability of the data during tax controversies but also to guide taxpayers during implementation. There is definitely still a role for economists on project teams, but CPAs are probably more conversant with such steps as making a compensating adjustment journal entry or quantifying FIN 48 risks (FASB Interpretation no. 48, Accounting for Uncertainty in Income Taxes, now codified in FASB ASC Topic 740) for financial reporting purposes.

Stuart Rohatiner, CPA, JD

Below are examples of transfer pricing issues where expert accounting skills are important:

Financial reporting. Certain industries have unique accounting revenue and expense treatment, and to calculate the appropriate benchmark ratios for transfer pricing purposes, an accountant needs to analyze the financial statement footnotes and understand which items are characterized as operating, pass-through, etc. For example, the income statements for a professional services firm include a special line item called “reimbursements” under the revenue and cost-of-sales categories. Reimbursements are generally pass-through contractor costs and reimbursed expenses and would likely be excluded from the operating revenue and operating expense calculations for transfer pricing purposes. In addition, with the currently volatile economy and corresponding impact on profitability, companies are increasingly monitoring their taxable income in each jurisdiction and likely making year-end compensating adjustments to the books and records to get profit margins within the arm’s-length ranges.

Transfer pricing audit document requests. The IRS and other tax authorities historically requested that taxpayers provide copies of their transfer pricing reports to support their pricing during audit years. Fast-forward to the current environment, and a typical audit request specifies tying the transfer pricing data from reports to general ledgers, consolidating income statements and balance sheets.

FIN 48 analysis. Public companies and their auditors are now required to analyze the income tax calculations and determine if the company needs to quantify and include in the financial statements any tax exposures that are “more likely than not” to be sustained upon examination. Auditors have increasingly identified transfer pricing risks, especially adjustments and penalties proposed by tax authorities, and forced taxpayers to disclose the details in SEC public filings and book reserves.

Reliability of financial data. Since much of transfer pricing financial analysis involves comparing unaudited financial statements with audited ones, a tax accountant who can validate the reliability of the unaudited data is invaluable, especially in tax controversy settings.

IRS analysis of adjustments and methods. The trend toward an increased focus on the accounting details of intercompany transactions may be a result of the IRS’ hiring international examiners with accounting backgrounds. Whatever the reason, the IRS has placed a new emphasis on reviewing all accounting and functional differences between the taxpayer-tested party and the comparable companies selected in the transfer pricing report. For example, during a recent meeting of a taxpayer with the IRS, the IRS international examiner compared each accounting line item from the taxpayer’s annual report with those of the comparable companies to make sure that adjustments were considered for any differences in functions or risks. Similarly, the examiner insisted on analyzing all potential transfer pricing methods and profit level indicators available, even though the IRS had agreed to the same method and profit level indicator with the taxpayer twice previously and the facts hadn’t changed significantly.

It shouldn’t come as a surprise that with the increasing complexity of transfer pricing and diminishing taxable income of corporations, the level of scrutiny by tax authorities has risen exponentially. In fact, in 2009, the IRS announced plans to hire an additional 800 agents in fiscal 2010 to focus on international examinations, and the agency’s proposed fiscal 2011 budget contains funding for 800 more. The field of transfer pricing will continue to grow and present employment opportunities for practitioners with the desired blend of economics and tax accounting skills.

 By Steve Snyder, CPA/CFF, CVA

Gotcha!

November 25, 2009
by Bob Williams on Fri 20 Nov 2009 08:00 AM EST  |

IRS Commissioner Doug Shulman reports that nearly 15,000 taxpayers turned themselves in under the service’s amnesty program for people who had failed to report overseas bank accounts on their federal income tax returns. A major inducement was the government’s settlement with Swiss bank UBS, under which the bank promised to hand over information on about 4,500 American account owners. More than 80 percent of the amnesty filings came after the IRS announced that settlement.

So why did more than 12,000 people fess up after they learned that UBS would report fewer than 5,000 of them? The key was that the IRS didn’t reveal the criteria UBS would use to pick accounts. Not knowing whether they were on the UBS list likely induced a lot of people to take advantage of the limited-time deal the IRS offered.

In a November 17 briefing, Shulman spelled out the UBS criteria, which surely exempted lots of accounts. UBS limited its list of accounts to those with balances of at least 250,000 Swiss francs (about $248,000) or annual revenue of at least 100,000 francs (about $99,000). But even for those accounts, owners had to have engaged in “fraud and the like” before the bank ratted them out—and UBS appears to have defined that phrase rather tightly. Hiding ownership through off-shore shell companies or using debit or credit cards to disguise withdrawals got you on the list. Simply owning an account did not. (Read more detail on the UBS criteria in David Hilzenrath’s story in the Washington Post.)

Last month Shulman said that people applying for amnesty reported account balances ranging “from just over $10,000 to over $100 million.” UBS apparently won’t report taxpayers—or should I say non-taxpayers—with accounts toward the lower end of that range. Some, perhaps many, of those who turned themselves in could have continued to hide their overseas assets without fear of being revealed, if only they’d known the UBS rules.

It’s likely that many people took the amnesty option to help them stop doing something they knew was wrong, even if they didn’t think their banks would report them. And others may have felt that UBS was only the first of many foreign banks that the U.S. will force to reveal account owners and decided to get in under the amnesty.

But because neither UBS nor the IRS explained the criteria during the amnesty period, a lot of people must have reported themselves for fear they’d show up on the UBS list.

Good move, IRS.

IRS Steps Up Witch Hunt for Secret Offshore Bank Accounts

October 15, 2009

Oct. 15 (originally reported by Bloomberg) — The IRS is intensifying its hunt for secret offshore banking, opening offices in Beijing, Sydney and Panama City after more than 7,500 Americans revealed undeclared accounts in 70 countries on six continents.

Internal Revenue Commissioner said yesterday Americans scared into coming forward before today’s deadline, which was manufactured to create a ‘false urgency’ on behalf of the sheep, have revealed accounts ranging in value from $10,000 to more than $100 million. The partial amnesty won’t be extended, he said, however then mumbled something like ‘again’, and winked and nudged this reporter.

Americans with undeclared offshore accounts have been under growing pressure since the US began inundating the media with stories of ‘cracking down’. In addition, in August, Switzerland agreed to hand over as many as 4,450 UBS AG accounts, from people who “didn’t matter” to settle a lawsuit in which the U.S. had sought as many as 52,000 accounts. (It has been revealed by UBS sources close to the matter that the list of 4450 accounts includes primarily widows, dentists, and the deceased — no bankers executives of fortune 500 companies with political contribution funds or politicians themselves have been included in the list.)

IRS Commissioner Shulman continued, “We’re going to be scouring the 7,500 disclosures to identify financial institutions, advisers and others who helped these serfs….uh i mean ‘taxpayers’ act like corporations,” the Commssioner said during a propoganda call with reporters. “This entire effort is not just about UBS and a single country.”

It isn’t yet known how much overlap might exist between the 4,500 names that UBS will eventually provide and the 7,500 people who have come forward to the IRS, Shulman said. However, great care went into properly informing those “in the know” that they were safe.

As part of its efforts to defraud and bully the American public into ‘compliance’, the IRS also intends to hire more than 800 new thugs in the next year and add staff to eight existing overseas offices, including Hong Kong and Barbados. “After all,” the Commissioner continued, “we’ve got to extract money from expats as well as just citizens. You don’t think you escape the long arm of the IRS just by leaving the country’s confines. Oh no. You were born into tax-slavery, you die in tax-slavery.”

After a reporter on the call reminded Shulman that some did ‘earn’ their freeman status by becoming part of the publically traded corporate elite, the Commissioner softened his statement slightly. “Alright, for those 1% of you destined to live on the backs of the other 99%, of course. But I’m talking to the ‘masses’ here.”

Back ‘on message’, he continued, “We have seen a very strong response to the program and I am very pleased with the results,” Shulman said.

Taxpayers disclosed assets that came from inheritances, profits skimmed from U.S. businesses, and international business transactions, he said.

“Clearly, assets cannot move from one generation to the other, profits cannot be strategically placed in tax havens, and profits generated outside the shores of the U.S. cannot be left to accumulate tax-free. It clearly states in tax law that these ‘exceptions’ are only available to corporations, who the supreme court says can take on the characteristics of a living person — for purposes of contract law. You see, corporations could just up and move….people, you see, we have them by the shorthairs.”

U.S. lawmakers praised the IRS program and called for stronger laws to help the agency. “We’ve done such a great job of enforcing the laws we already have on the books to avoid fraud and limit the growth and scope of the Federal Reserve, what we really need are more laws,” said Senator Shumer in a press release in support of the IRS victory.

Senator Carl Levin, a Michigan Democrat whose Permanent Subcommittee on Investigations has held two hearings into how UBS solicited Americans to put assets in Swiss banks, said he’ll keep pushing legislation to give the IRS more tools. He said he plans to offer his proposal as an amendment to a health-care measure the Senate will debate later this year.

“Hell, if I can’t get more power to the IRS in a standalone bill, I’ll just sneak it into a 9000 page bill on ‘healthcare reform’. They’ll be so busy arguing over the actual bill, they’ll never even notice this little added ‘treasure’ at the end. And besides, who wouldn’t want to take care of the sick and the elderly? It’s ‘un-American’, ” Levin said.

Levin continued, “Luckily, many Americans are losing confidence in the ability of tax-haven banks to secure what’s rightfully theirs from the grasping claws of the government and frivilous lawsuits in an unjust legal system,” Levin said. “But it is also clear that thousands of other taxpayers are still in the shadows, working to secure what they’ve rightfully earned, and keep their offshore accounts hidden from the politicians and judges who know better how their wealth should be distributed.”

Montana Democrat Max Baucus, chairman of the Senate Finance Committee that oversees the IRS, is drafting his own legislation to double financial penalties on those who avoid taxes by moving money offshore.

‘A Start’

He called the 7,500 disclosures “a start” that demonstrates the IRS propoganda is working.

“With record deficits and a weakened economy, we owe it to politicians, and government employees (myself included) to set an aggressive agenda that puts an end to offshore tax avoidance once and for all,” Baucus said. “After all, I’m a public employee to, and if you kill of overly generous pay, benefits and pensions to lawmakers and public employees, I’d have to earn an honest living by adding value somewhere.”

Under the IRS program announced in March, the confiscation will take 20 percent of an account’s assets based on its peak value in the previous six years. Luckily, in many cases, these peak years include the heady year of 2006.

“We feel this program enables us to advertise that it’s only 20 percent, lure some suckers in, and then take about half of what’s remaining since the depress—er, i mean recession has halved most of these accounts from peak,” the Commissioner said.

Ordinarily, the IRS can seize the higher of $100,000 or 50 percent of an offshore account’s value when the holder deliberately doesn’t disclose the account to the Treasury Department. The penalty can apply each year that required forms aren’t filed, so after three years of noncompliance an account holder can owe 150 percent of the account’s value.

An IRS representative speaking on condition of anonymity said, “Hey, look, we rely on voluntary disclosure, hence all the propoganda and fear tactics…Regarding the 150 percent: well, clearly, you didn’t think you were allowed to work for your own benefit did you? Your life belongs to the state.”

Avoiding Prosecution

People who come forward voluntarily can avoid criminal prosecution and their identities will remain a secret under federal law requiring tax records to be kept confidential.

George Clarke, a tax lawyer at the Washington-based Miller & Chevalier firm, who is representing about 20 people seeking leniency in the program, said the IRS’s announcement indicates the agency is positioning itself to more efficiently hunt tax cheats.

“Look, in half these cases it’s some poor schmuck who’s worked his entire life for some assets and doesn’t want a cheating wife or frivilous lawsuit to drain him like an above ground pool,” he said. “If they agree to keep it on the hush hush and out of public light, the sheep are more willing to line up and be sheered — If it’s just the IRS, they are less likely to lose their balls to a divorce settlement or ‘personal injury’ lawsuit. It’s a brilliant approach, really.”

Shulman said the IRS is building on the information it has received, and declined to estimate how much money the IRS will capture.

“You add this huge media and propoganda blitz up and it means equals voluntary disclosure and compliance for the vast majority of sheeple thinking about hiding assets offshore,” Shulman said. “If I had to justify this on captured assets alone, the revenue wouldn’t begin to approach the costs.”

He continued, “It’s like a prison. A few guards have to keep a lot of prisoners at bay through fear and intimidation. In the coming weeks and months, as tax receipts plummet and deficit spending soars into the teeth of a global collapse, the saber rattling by the IRS will become deafening.”

The voluntary disclosure program isn’t available to widows or dentists already under scrutiny by the IRS. Since December 2007, six UBS clients have pleaded guilty and a seventh has agreed to do so. A UBS banker pleaded guilty; two were indicted; and three Europeans were charged with enabling U.S. tax evasion.

The Justice Department has said 150 taxpayers, and no corporations, banks, charities, goldman sachs employees, or ‘religious institutions’ are under criminal investigation.

The IRS has announced that information is available about the voluntary disclosure practice for those with undisclosed offshore accounts in six additional languages.

October 10, 2009

The IRS has announced that information is available about the voluntary disclosure practice for those with undisclosed offshore accounts in six additional languages. The a gency took this step in order to reach taxpayers whose primary language may not be English. Information related to the special Oct. 15, 2009 deadline for undisclosed offshore accounts and a one-page overview of the voluntary disclosure practice are available in Chinese, French, Korean, Russian, Spanish and Vietnamese on IRS.gov

New York Urges Taxpayers To Report Income From Offshore Bank Accounts

October 9, 2009

New York Urges Taxpayers To Report Income From Offshore Bank Accounts
NYS Voluntary Disclosure and Compliance Program is Opportunity to Come Forward and Pay Back Taxes and Avoid Possible Criminal Prosecution

ALBANY, NY (10/08/2009)(readMedia)– New York State Department of Taxation and Finance Acting Commissioner Jamie Woodward today announced that New York taxpayers who invested in offshore bank accounts or other offshore activity are required to report to the state Tax Department any changes in their taxable income resulting from a federal audit or from the filing of an amended federal return.

Former and current New York State residents should review their state tax returns to determine if they need to file amended returns to report this income.

Eligible New York taxpayers should also consider New York State’s Voluntary Disclosure and Compliance (VDC) Program. Under the VDC program, eligible taxpayers can avoid monetary penalties and possible criminal charges by disclosing what taxes they owe, paying the tax and entering into an agreement to pay all future taxes.

This urging comes on the heels of the Internal Revenue Service’s (IRS) recent successful court battle and its aggressive action to force foreign financial institutions to disclose the names of taxpayers who currently have unreported offshore income or who previously had undisclosed foreign accounts or entities.

The IRS is currently offering a voluntary disclosure program for federal tax liabilities on unreported offshore income.

Taxpayers who participate in the federal program are required to file or amend their federal tax returns. The application deadline for federal leniency is October 15, 2009 and detailed information can be found on the IRS’ website at http://www.irs.gov.

New York taxpayers who participate in the IRS’ voluntary disclosure program and file or amend their federal tax returns are urged to report any changes made in their taxable income to New York State in a timely manner in order to avoid the possible penalties for failing to report federal changes.

The IRS and New York State have agreements to share information between the two agencies. Information received from federal amended returns and from foreign governments will ultimately be shared with New York State authorities.

The required forms and instructions on filing an amended New York tax return are available on the tax department’s website at http://www.tax.state.ny.us/forms/default.htm.

Information and an easy four-step application process for eligibility to New York State’s VDC Program are available online at http://www.tax.state.ny.us/e-services/vold/default.htm.

Offshore Account Voluntary Disclosure Deadline Extended to Oct. 15

September 22, 2009

SEPTEMBER 21, 2009
The IRS today extended the deadline for voluntary disclosures by taxpayers with unreported income from hidden offshore accounts from this Wednesday, Sept. 23, to Oct. 15. The IRS cautioned that there would be no further extensions.

The IRS said that tax practitioners had requested an extension because some are having trouble interviewing and advising the large number clients who have come to them for help. The deadline extension is designed to help taxpayers who “had intended to come forward prior to the deadline, but faced logistical and administrative challenges in meeting it,” according to the IRS.

The voluntary disclosure program was announced in March. Taxpayers making voluntary disclosures of offshore noncompliance under the program can avoid the foreign bank and financial account balance nondisclosure penalty provisions and other provisions pertaining to various information returns.

Taxpayers who have properly reported their taxable income but did not realize that they had an obligation to file Form TD 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR), were also given until Sept. 23 to file all delinquent FBARs. It is unclear from the IRS announcement whether the Oct. 15 extension also applies to them.

The IRS subsequently updated its voluntary disclosure FAQ Web page to reflect (and the AICPA FBAR Task Force confirmed with the IRS) that even if no income is underreported and the voluntary disclosure process is not being used by a taxpayer, other relevant delinquent information returns covered by the voluntary disclosure FAQs (that is, FBARs noted in FAQ no. 9, and forms 3520 and 5471 noted in FAQ no. 42) also have an extended filing deadline of Oct. 15, 2009.

IRS extends amnesty for international tax dodgers

September 21, 2009

The Associated Press

Published: September 20, 2009

WASHINGTON – The IRS is extending the Wednesday deadline for international tax dodgers to apply for an amnesty program in order to give a rush of applicants more time to prepare their paperwork.

More than 3,000 Americans hiding assets overseas have applied for the program, which promises no jail time and reduced penalties for tax cheats who come forward, said a government official who spoke on condition of anonymity.

The Internal Revenue Service plans to announce Monday that the program will be extended until Oct. 15, said the official, who was not authorized to speak on the record ahead of the public announcement.

The IRS long has had a policy that certain tax evaders who come forward before they are contacted by the agency usually can avoid jail time as long as they agree to pay back taxes, interest and hefty penalties. Drug dealers and money launderers need not apply. But if the money was earned legally, tax evaders can usually avoid criminal prosecution.

Fewer than 100 people apply for the program in a typical year, in part because the penalties can far exceed the value of the hidden account, depending on how long the account holder has evaded U.S. taxes.

But in March, the IRS began a six-month amnesty program that sweetened the offer with reduced penalties for people with undeclared assets.

As the initial deadline approached, the IRS was contacted by tax advisers from across the country requesting more time to prepare applications from a rush of tax cheats looking to come clean, the government official said.

The amnesty program is part of a larger effort by federal authorities to crack down on international tax evaders. In August, the U.S. and Switzerland resolved a court case in which Swiss banking giant UBS AG agreed to turn over details on 4,450 accounts suspected of holding undeclared assets from American customers.

The process of turning over that information is expected to take several months. But once the IRS obtains information about international tax dodgers, they will be ineligible for the amnesty program.

Publicity from the UBS case, even before the agreement was announced, had many wealthy Americans with offshore accounts nervously running to their tax advisers.

Lawyers and advisers from several firms have said they were swamped with calls from people hiding assets overseas. Their advice: Call the IRS before the IRS calls you.