Effectively Representing the Client in a Voluntary Disclosure of a Foreign Account
by Asher Rubinstein, Esq.
We have represented and advised many clients in the 2009 Offshore Voluntary Disclosure Program (OVDP), the 2011 Offshore Voluntary Disclosure Initiative (OVDI) and have already begun advising clients regarding the recently-announced 2012 revival of the OVDI.
From our involvement in many voluntary disclosures, we have heard a significant number of people reporting their their prior attorneys and advisors have not effectively represented the client’s interests before the IRS. Many people have reported to us that their advisors have “pressured” them into making disclosures, instilling a fear of either making a voluntary disclosure or “going to jail”. Other advisors were little more than paper-pushers, taking foreign banking statements and other documents, and simply turning them over to the IRS with little to no advocacy on behalf of the clients. While practitioners may be correct
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