Massachusetts IRS Compliance Lawyer
Theodore L. Craft, Attorney at Law and Tax Counsel represents clients who have been participants in abusive offshore tax schemes of one variety or another. Historically, the Internal Revenue Service has initiated programs for voluntary disclosure of offshore or other tax advantaged arrangements which are fraudulent or abusive in some way by reason of hiding assets or avoiding [usually income, but also estate] taxation. In these programs, a letter may be sent to a taxpayer by IRS stating that the taxpayer has been identified in such a scheme, and inviting the client's cooperation in an investigation into their activities. The involvement may go back several years; years as to which the IRS could only assess additional income tax if it asserted the fraud penalty in order to keep the assessment period open under the tax assessment statute.
Many times, where a client may be notified that he is a target of a criminal investigation for being a participant in an abusive tax shelter. In such cases, the client may have been a victim of an unscrupulous promoter selling what the Internal Revenue Service sees as nothing more than snake oil, that is, tax advantages which have no "economic substance" or "business purpose" and hide income or assets from view behind a veil, so that IRS cannot see the true nature of what activity is taking place.
The IRS view in either case is that in the transaction or series of transactions in which the client has been involved, but has hidden behind artificial barriers to transparency, the taxpayer merely attempts to abuse the tax system.
Have You Been Accused of Hiding Assets in an Offshore Bank Account?
The biggest mistake you can make is to underestimate the seriousness of such matters. The unknown is measured from the point of view of one's perspective on it. While no tax lawyer can predict a future outcome, perspective is everything. In any offshore bank account tax investigative matter, under no circumstance it is a good idea to speak to a special agent of the Internal Revenue Service without first consulting a lawyer.
Theodore L. Craft is an experienced Boston tax lawyer with a complete understanding of substantive and procedural criminal tax law. Contact his law office in Melrose, Massachusetts, if you are the subject of an IRS audit for alleged tax avoidance and there is involvement in the way of money concealed from IRS scrutiny through an offshore tax arrangement.
More Information on Offshore Tax Arrangements
See the following pages of the website for more information on offshore tax arrangements:
- Foreign accounts offshore voluntary disclosure initiative
- Criminal tax fraud in offshore tax arrangements
Look to the following private and Government sites [The United States Department of Justice reading room and press releases in particular] to read further about prosecution of offshore tax scams and abusive tax shelters:
- http://www.usdoj.gov/opa/ - Search "Press Room and Tax"
- www.usdoj.gov/tax - Search "Tax News" and "Press Releases"
- http://www.usdoj.gov/tax/readingroom/2008ctm/TaxManual2008.htm - Department of Justice Tax Division Criminal Tax Manual
- http://meetings.abanet.org/webupload/commupload/IC650004/relatedresources/4.1.pdf- This is a link to an article published as part of an American Bar Association OVDI and FBAR Guidance Teleconference dated March 16, 2011