Tax-Expatriation

GAO Yr2014 Report on Offshore Voluntary Disclosure Program Indicates Less Than 4% of Taxpayers Lived Outside the U.S.

Posted on March 11, 2014 Updated on April 25, 2015

The GAO has now issued two reports on taxpayers who participated in the  Offshore Voluntary Disclosure Programs.  See, The 2013 GAO Report  of the IRS Offshore Voluntary Disclosure Program, International Tax Journal, CCH Wolters Kluwer, January-February 2014.

The extensive March 2013 GAO Report was followed by this year’s January 2014 GAO Report of 10,533 taxpayers analyzed; all of which participated in the 2009 OVD program.  Interestingly, the report identifies the countries where the accounts were located; with Switzerland being the predominant country.  See Table II below from the report –

In addition, the report identified the location of the taxpayers.  Not surprisingly, the states with the greatest populations, such as California, New York and Florida had the states with the greatest number of taxpayers participating in the OVD program.  There is, however, no direct correlation to the population in those states and the number of OVD filers.  

Most interesting for U.S. citizens and LPRs living outside the U.S., are the 457 addresses identified as “other addresses”.  These “other addresses” include P.O. addresses, such as from Army Post Offices, residents of Puerto Rico, income earned by U.S. government employees and “other U.S. citizens abroad.”

How many of these 457 addresses are U.S. citizens living permanently outside the U.S. who are “Accidental Americans”?  How many (if any) are LPRs living permanently outside the U.S.?

A more comprehensive list of the countries where the accounts were located is listed in Table 2 from this report.

Switzerland dominates the list with 42% of the accounts.  See, Is the new government focus on U.S. citizens living outside the U.S. misguided or a glimpse at the new future? – with the Permanent Subcommittee on Investigations focusing primarily on Swiss Banks and Swiss accounts.

The UK is number two on the list with 1,058 accounts.   Interestingly, Canada is number three on the list with 4%, presumably due to many dual nationals living in Canada.

India has only 2% of the accounts reported from this 2009 program, but has become a clear focus of the U.S. federal government.  See, U.S. Justice Department Seeks Information on HSBC Customers with Offshore Accounts regarding the John Doe summonses filed with a San Francisco federal judge regarding HSBC accounts in India.

In addition, the Criminal Investigation office of the IRS in Northern California reported at the Annual California Tax Bars meeting in October 2013 in San Jose, California, that their office had just received a number of cases from India regarding unreported foreign accounts (part of a nationwide distribution of cases centered in India).

请点击这里查看本帖子的中文版本。 （Please click here to view the above in Chinese.）