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Are You a Taxpayer That Needs to Circle September 28 on Your Calendar?


Our principal attorney at the long-tenured Bay Area Law Offices of John W. Noonan has a deep well of experience representing diverse clients in both state and federal criminal matters.

There can be a world of difference between those two spheres, as we note on our website. Federal investigations, for example, often feature manpower, resources and extended time commitments that are simply unmatched in state criminal probes. Moreover, post-conviction reality is often comparatively dismal for a defendant in a federal case, given the long prison terms that are often handed down in such matters.

The list of federal charges is long, with tax evasion and fraud obviously being a central entrant and focus for federal task forces.

That primarily means the IRS, of course, with that agency commanding strong powers through a variety of enforcement programs.

One of those initiatives is spotlighted in a recent article written by a former tax official with the U.S. Department of Justice. Ex-DOJ Tax Division chief Caroline Ciraolo notes the scheduled termination on September 28 of this year of the Offshore Voluntary Disclosure Program.

That initiative was established in 2009 to encourage Americans with undisclosed foreign assets to voluntarily come forward. The “carrot” approach of the OVDP emphasizes that voluntary compliance will yield less harsh outcomes for willful nonfilers than is the case when the IRS brings charges against them following a criminal investigation.

Ciraolo believes that a “stick” approach might now logically emerge in the wake of the OVDP’s termination. She suggests that select filers with bona-fide criminal law concerns take advantage of the still-open OVDP window that is rapidly closing.

Such individuals might also want to consult with an attorney experienced in federal criminal defense matters, including tax fraud.