The Use of Voluntary Disclosure Initiatives in the Battle Against Offshore Tax Evasion
Indiana University Maurer School of Law
Villanova Law Review, Vol. 57, 2012
Indiana Legal Studies Research Paper No. 200
The federal government has engaged in a number of well-publicized enforcement efforts in an attempt to collect back taxes owed on offshore bank account and other offshore assets. Among those efforts are special offshore “voluntary disclosure” initiatives — essentially tax amnesties — offered by the Internal Revenue Service. One such program closed in September 2011, and another opened in January 2012. After discussing the history of voluntary disclosure programs, particularly the offshore initiatives of 2003, 2009, 2011, and 2012, this essay evaluates the government’s approach to voluntary disclosure of offshore evasion in light of the literature on optimal tax amnesties. The essay concludes that the offshore tax amnesties meet some but not all of the elements of an optimal amnesty.
Number of Pages in PDF File: 31
Keywords: Tax compliance, tax evasion, voluntary disclosure, tax amnesty, FATCA, FBAR, UBS, offshore bank accounts
JEL Classification: H26, K34, K42
Date posted: January 31, 2012 ; Last revised: July 11, 2013
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