31 Pages Posted: 31 Jan 2012 Last revised: 11 Jul 2013
Date Written: 2012
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.
Keywords: Tax compliance, tax evasion, voluntary disclosure, tax amnesty, FATCA, FBAR, UBS, offshore bank accounts
JEL Classification: H26, K34, K42
Suggested Citation: Suggested Citation
Lederman, Leandra, The Use of Voluntary Disclosure Initiatives in the Battle Against Offshore Tax Evasion (2012). Villanova Law Review, Vol. 57, 2012; Indiana Legal Studies Research Paper No. 200. Available at SSRN: https://ssrn.com/abstract=1993323 or http://dx.doi.org/10.2139/ssrn.1993323