The assistant US attorney general for the Tax Division, Kathryn Keneally, recently indicated that the window for avoiding criminal prosecution related to undeclared foreign accounts may be closing soon.  At a roundtable discussion at the University of Southern California’s annual tax institute, Ms. Keneally indicated that waiting to disclose offshore accounts is extremely dangerous. 

If you have undeclared offshore accounts, you should consult with a tax attorney who regularly handles such disclosures.  Taxpayers who would like more information regarding the 2012 IRS Voluntary Disclosure Program should call Jim Mastracchio at (202) 861-1650 or Jennifer Benda at (303) 764-4025.