Countries throughout the world have committed to redefining banking secrecy laws so as to no longer protect any form of tax offense and/or adopt more stringent information sharing standards in tax matters. The shift to greater transparency and information sharing has caused an increase in the number of individuals seeking to divulge previously unreported income. Several jurisdictions now offer various streamlined measures or amnesty programs for such taxpayers in an effort to get individuals back into the tax net.
The United States has long had a ‘voluntary disclosure’ program, but has recently announced new rules for individuals with offshore investments wishing to ‘come clean’.
In the current climate of increased information exchange under the Foreign Account Tax Compliance Act, Congressional Investigations, IRS lawsuits against international financial institutions and Justice Department investigations of individuals and foreign banks, an ever-increasing number of US taxpayers have expressed an interest in reviewing their tax and information reporting obligations. Likewise, many financial advisers and fiduciaries are reviewing their internal procedures in light of current ‘best practice’ in servicing their US clients.