By Jay R. Nanavati & Justin A. Thornton
Criminal Justice, Volume 29, Number 2, Summer 2014
American Bar Association
The US government continues to hammer away at the use by US taxpayers of foreign secrecy jurisdictions to evade taxes. Beginning with its highly publicized takedown of UBS in 2008 and continuing through the current Offshore Voluntary Disclosure Program (OVDP), the Department of Justice (DOJ) and the Internal Revenue Service (IRS) are using both carrots and sticks to coax taxpayers to bring their money back into the “system.” The government’s fiscal difficulties of the last five years have only added urgency to the crackdown.