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For more than seven years, the Internal Revenue Service (IRS) has had formal programs in place that allow certain US taxpayers to avoid significant penalties for prior failures to comply with certain filing and reporting obligations related to previously undisclosed foreign assets. However, earlier this year, Caroline Ciraolo, Acting Assistant Attorney General of the Department of Justice (DOJ) Tax Division, said, "After three very wellpublicized voluntary disclosure programs, nearly 200 criminal prosecutions, ongoing criminal investigations, and the increasing assessment and enforcement of substantial civil penalties for failure to report foreign financial accounts, a taxpayer's claims of ignorance or lack of willfulness in failing to comply with disclosure and reporting obligations are, quite simply, neither credible nor well-received." Ciraolo's statement was made at the annual meeting of the Federal Bar Association Section on Taxation in Washington. Her statement illustrates the US government's skepticism that there could possibly still be any US taxpayers in various parts of the world who are unaware of their US filing and reporting obligations. While the level of media attention surrounding the US government's pursuit of noncompliant taxpayers has kept the issue in the financial press, that does not mean that the current level of public awareness negates a taxpayer's previous lack of knowledge.
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