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<\/a>Reporting on a California State Bar Tax Section Meeting, Tax Notes reports that the IRS will soon (as early as the week of 11\/11\/13) ) \u201cbegin examining U.S. taxpayers suspected of holding undeclared accounts in Indian banks, according to Nicholas Connors, a supervisory revenue agent\u201d with SB\/SE.<\/p>\n\n\n\n
Some excerpts:<\/p>\n\n\n\n
After receiving account information from Indian banks, the IRS has about 100 Indian bank account cases that it is sending out for examination across the country, he said.<\/p>\n\n\n\n
\u201cI think California, because of the large Indian population, is going to get more than its fair share of cases,\u201d Connors said. \u201cWithin the Northern California\/Bay Area, we\u2019re scheduled to pick up 30 or 40 of those.\u201d<\/p>\n\n\n\n
\u201cLooking ahead, the offshore bank investigations are just going to grow,\u201d Connors said. In addition to India, \u201cIsrael is on the list of banks that is providing information to us, and from there it just keeps going on and on,\u201d he said. \u201cWithin Examination, there\u2019s talk that this could someday become a work issue for every single revenue agent in SB\/SE where everyone will be working some type of offshore case.\u201d<\/p>\n\n\n\n
Regarding Quiet Disclosures, Tax Notes reports:<\/p>\n\n\n\n
The SEP team continues to examine quiet disclosures as well as cases regarding taxpayers who opted out of the IRS offshore voluntary disclosure program (OVDP), said Connors. \u201cThe guidance we\u2019re getting on quiet disclosures has been extremely harsh,\u201d he said. \u201cEssentially those taxpayers walked past compliance three times: They didn\u2019t file correctly the first time, they didn\u2019t come in under voluntary disclosure, and now they\u2019re trying to hide it by slipping it in through an amended return. Don\u2019t expect much leniency if we have a quiet disclosure case; agents are being told to be aggressive.\u201d<\/p>\n