IRS has aggressively pursued injunctions and prosecution of promoters of Abusive Tax Avoidance Schemes. These transactions have been widely known as Abusive Tax Avoidance Transactions (ATAT).  Read more http://www.irs.gov/businesses/small/article/0,,id=106788,00.html

IRS has expanded the program to include Abusive Offshore Tax Avoidance Schemes.  Since the UBS settlement IRS has aggressively pursued Abusive Offshore Tax Avoidance Schemes.  Read more http://www.irs.gov/businesses/small/article/0,,id=106568,00.html

It is important to undestand that all offshore accounts are not abusive or illegal.  If you have an offshore account or are concerned about your reporting requirements you should take action to learn more.  We have worked with over 80 clients with offshore accounts.  Call for a free confidential consultation at 1-800-447-6181.