The scenario shows many examples of fraudulent taxpayer behavior, including a typical “cash skim”,kept a second set of books, payment of personal expenses, and accumulation of a “horthort” (albeit in the form of gold bars). Outside of the voluntary opening process, there is no doubt that an IRS agent would be worth it for civil fraud for several years. Since this is a case of self-denunciation, the penalty of civil fraud is limited to a single year, a substantial concession to the taxpayer. As soon as the LB&I Austin unit receives information from the IRS-CI, it will forward the case for review. If a taxable person or representative wishes to make a payment with an examiner before being assigned to the case, payments may be made to the LB &I Austin unit. LB&I Austin-Einheit selects the last fiscal year covered by the volunteering obligation for review and then forwards cases and land allocation files to the corresponding business operating division and audit function for civil review. All self-reports are conducted according to normal review procedures. Auditors should develop records, use appropriate tools to gather information (e.g. B requirements for fact sheets and summonses) and set appropriate tax obligations and penalties. In another way, the new procedures differ considerably, in particular the new civil sanctions framework.
Taxpayers who now use the updated voluntary opening program may face a 50 percent fine on their undisclosed offshore financial assets and a 75 percent civil fraud penalty for unpunished taxes, and both penalties can be applied for several years in certain circumstances. . . .