Abstract

http://ssrn.com/abstract=2313266
 


 



Whistle-Blower Awards and the Bank Secrecy Act: Mutually Exclusive?


Charles P. Rettig


Hochman, Salkin, Rettig, Toscher & Perez, P.C.

February 2013

Journal of Tax Practice & Procedure, CCH-Wolters Kluwer Publishers, pp. 23-29, Feb.-March 2013

Abstract:     
Tax whistle-blowers provide valuable leads and often offer unique insights to compliance challenged taxpayers. The IRS must act promptly when receiving specific and credible information regarding tax compliance issues when that information can be corroborated through examination activity. In these situations, the IRS Whistle-Blower Office is charged with processing financial awards to people who provide information about the tax indiscretions of others.

Although ongoing tax-related enforcement actions have generated payment of considerable penalties associated with violations of the Bank Secrecy Act in a Memorandum for Stephen A. Whitlock, Director of the IRS Whistle-Blower Office, IRS Counsel determined that these BSA-related recoveries may not be considered for purposes of computing the amount of the award under Code Sec. 7623.

The whistle-blower statute is intended to provide valuable leads to the IRS which effectively preserves other precious tax enforcement resources. Information provided by whistle-blowers is helpful when IRS resources are being stretched thin and compliance functions curtailed. Further, a visible, well-respected IRS whistle-blower program increases public interest in the program and could cause countless otherwise compliance-challenged taxpayers to voluntarily comply ... deterrence can be a persuasive and relatively inexpensive tax enforcement tool.

Number of Pages in PDF File: 7

Keywords: BSA, tax whistle-blower, FBAR, IRS, tax enforcement, OVDP, OVDI

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Date posted: August 21, 2013  

Suggested Citation

Rettig, Charles P., Whistle-Blower Awards and the Bank Secrecy Act: Mutually Exclusive? (February 2013). Journal of Tax Practice & Procedure, CCH-Wolters Kluwer Publishers, pp. 23-29, Feb.-March 2013. Available at SSRN: http://ssrn.com/abstract=2313266

Contact Information

Charles P. Rettig (Contact Author)
Hochman, Salkin, Rettig, Toscher & Perez, P.C. ( email )
9150 Wilshire Blvd., Suite 300
Beverly Hills, CA 90212
United States
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