There is a possibility that the government may reject your request to enter the Streamlined Program because it believes you acted willfully by hiding your offshore accounts from the IRS.
If that happens, you may face criminal investigation and prosecution for failure to properly disclose the offshore accounts and unreported income from the offshore accounts.
The potential of a criminal conviction is a serious matter which should be analyzed by a criminal defense lawyer who is experienced in defending criminal tax investigationsand prosecutions. The issue of willfulness is an element of all criminal tax cases as well as the failure to file the yearly forms disclosing the offshore accounts.
The Streamlined Program does not offer immunity from prosecution but the OVDP does. A criminal defense lawyer experienced in tax cases can analyze the risks and benefits of each program so that the client can make an informed decision.
To speak with an experienced criminal defense attorney about your case, contact the Law Offices of Mark L. Horwitz today.