OFFSHORE TAX 

EVASION

IRS Has Collected 

Billions of Dollars, but 

May be Missing 

Continued Evasion

Report to Congressional Requesters

March 2013

GAO-13-318

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-13-318, a report to 

congressional requesters 

March 2013 

OFFSHORE TAX EVASION

IRS Has Collected Billions of Dollars, but May Be 

Missing Continued Evasion

Why GAO Did This Study

Tax evasion by individuals with 

unreported offshore financial accounts 

was estimated by one IRS 

commissioner to be several tens of 

billions of dollars, but no precise figure 

exists. IRS has operated four offshore 

programs since 2003 that offered

incentives for taxpayers to disclose 

their offshore accounts and pay 

delinquent taxes, interest, and 

penalties. GAO was asked to review

IRS’s second offshore program, the 

2009 OVDP. This report (1) describes 

the nature of the noncompliance of

2009 OVDP participants, (2) 

determines the extent IRS used the

2009 OVDP to prevent noncompliance, 

and (3) assesses IRS’s efforts to 

detect taxpayers trying to circumvent 

taxes, interests, and penalties that 

would otherwise be owed. To address 

these objectives, GAO analyzed tax 

return data for all 2009 OVDP 

participants and exam files for a 

random sample of cases with penalties 

over $1 million; interviewed IRS 

Offshore officials; and developed and 

implemented a methodology to detect 

taxpayers circumventing monies owed. 

What GAO Recommends

Among other things, GAO 

recommends that IRS (1) use offshore 

data to identify and educate taxpayers 

who might not be aware of their 

reporting requirements; (2) explore 

options for employing a methodology 

to more effectively detect and pursue 

quiet disclosures and implement the 

best option; and (3) analyze first-time

offshore account reporting trends to

identify possible attempts to 

circumvent monies owed and take 

action to help ensure compliance. IRS 

agreed with all of GAO’s 

recommendations.

What GAO Found

As of December 2012, the Internal Revenue Service’s (IRS) four offshore 

programs have resulted in more than 39,000 disclosures by taxpayers and over 

$5.5 billion in revenues. The offshore programs attract taxpayers by offering a 

reduced risk of criminal prosecution and lower penalties than if the unreported 

income was discovered by one of IRS’s other enforcement programs. For the 

2009 Offshore Voluntary Disclosure Program (OVDP), nearly all program 

participants received the standard offshore penalty—20 percent of the highest 

aggregate value of the accounts—meaning the account value was greater than 

$75,000 and taxpayers used the accounts (e.g., made deposits or withdrawals) 

during the period under review. The median account balance of the more than 

10,000 cases closed so far from the 2009 OVDP was $570,000. Participant 

cases with offshore penalties greater than $1 million represented about 6 percent 

of all 2009 OVDP cases, but accounted for almost half of all offshore penalties.

Taxpayers from these cases disclosed a variety of reasons for having offshore 

accounts, and more than half of them had accounts at Swiss bank UBS. 

Using 2009 OVDP data, IRS identified bank names and account locations that 

helped it pursue additional noncompliance. Based on a review of cases, GAO

found examples of immigrants who stated in their 2009 OVDP applications that 

they were unaware of their offshore reporting requirements. IRS officials from the 

Offshore Compliance Initiative office said they have not targeted outreach efforts 

to new immigrants. Using information from the 2009 OVDP, such as the 

characteristics of taxpayers who were not aware of their reporting requirements, 

to increase education and outreach to those populations could promote voluntary 

compliance.

IRS has detected some taxpayers with previously undisclosed offshore accounts 

attempting to circumvent paying the taxes, interest, and penalties that would 

otherwise be owed, but based on GAO reviews of IRS data, IRS may be missing 

attempts by other taxpayers attempting to do so. GAO analyzed amended 

returns filed for tax year 2003 through tax year 2008, matched them to other 

information available to IRS about taxpayers’ possible offshore activities, and 

found many more potential quiet disclosures than IRS detected. Moreover, IRS 

has not researched whether sharp increases in taxpayers reporting offshore 

accounts for the first time is due to efforts to circumvent monies owed, thereby 

missing opportunities to help ensure compliance. From tax year 2007 through tax 

year 2010, IRS estimates that the number of taxpayers reporting foreign 

accounts nearly doubled to 516,000. Taxpayer attempts to circumvent taxes, 

interest, and penalties by not participating in an offshore program, but instead 

simply amending past returns or reporting on current returns previously 

unreported offshore accounts, result in lost revenues and undermine the 

programs’ effectiveness. 

View GAO-13-318. For more information, 

contact James R. White, (202) 512-9110 or 

whitej@gao.gov. 
Page i GAO-13-318 Offshore Tax Evasion

Letter 1 

Background 3

Almost All 2009 OVDP Participants Received the Maximum 

Offshore Penalty, Almost Half Had Accounts in Switzerland, and 

About Half of the Revenue Collected Came from A Small 

Percentage of High Penalty Cases 12

IRS Generally Has Used 2009 OVDP Data Strategically, But Has Not 

Used the Data to Identify Additional Opportunities to Educate 

Taxpayers on Offshore Filing Requirements 18

IRS May Not Be Identifying a Large Number of Quiet Disclosures 

or Other Attempts to Circumvent Some of the Taxes, Interest 

and Penalties that would be Otherwise Owed by Not 

Participating in an Offshore Program 23

Conclusions 28

Recommendations for Executive Action 29

Agency Comments 30

Appendix I Objectives, Scope and Methodology 32

Appendix II Events that Influenced Participation in IRS’s Offshore 

Programs 36

Appendix III Sample 2009 and 2012 Offshore Program Application Letters 39

Appendix IV Hypothetical Examples Comparing Account Balances, 

Length of Account Ownership, and Penalties 50

Appendix V 2009 Offshore Voluntary Disclosure Program Participants 

with Employer Identification Numbers 53

Contents 
Page ii GAO-13-318 Offshore Tax Evasion

Appendix VI Additional 2009 Offshore Voluntary Disclosure Program 

Participant Characteristics 55

Appendix VII Data Collected from a Sample of 30 2009 Offshore Voluntary 

Disclosure Program Case Files with Large Penalties 56

Appendix VIII Quiet Disclosure Analysis Results 60

Appendix IX Comments from the Internal Revenue Service 61

Appendix X GAO Contact and Staff Acknowledgments 65

Tables

Table 1: Comparison of IRS’s Offshore Voluntary Disclosure 

Programs 10

Table 2: Selected Penalty Information for 2009 OVDP Individual 

Taxpayers with Closed Cases as of November 29, 2012 13

Table 3: Type and Amount of Offshore Penalties for 2009 OVDP 

Closed Cases (Individual Taxpayers) as of November 29, 

2012 13

Table 4: 2008 Business Filing Requirements for 2009 OVDP 

Business Participants 53

Table 5: Self-Reported Industry Code on 2008 Tax Return for 2009 

OVDP Businesses 53

Table 6: Taxpayer and 2009 OVDP Participant Income and 

Demographics for Tax Year 2008 55

Table 7: Selected Offshore Account Balances, Taxes, and Penalties 

from a Case Study of 30 2009 OVDP Cases with Penalties 

of $1 Million or Greater 56

Table 8: Selected Data Collection Instrument Questions and 

Response Counts from Sample of 30 2009 OVDP Case Files 

with Penalties of $1 Million or Greater 59
Page iii GAO-13-318 Offshore Tax Evasion

Figures

Figure 1: Illustration of Taxpayer and Information Reporting on 

Offshore Accounts 5

Figure 2: IRS Process for Developing Offshore Disclosure 

Programs 6

Figure 3: Top Ten Locations of Offshore Accounts on 2008 FBARs 

Filed by 2009 OVDP Participants Compared to All 2008 

Individual FBAR Filers 14

Figure 4: Taxpayers Reporting Foreign Financial Accounts 27

Figure 5: Events That Influenced Participation in IRS’s Offshore 

Programs 38

Figure 6: Hypothetical Comparison of Offshore Account Growth 

for Compliant (Reported and Taxed) and Noncompliant 

(Unreported and Untaxed) Taxpayers, and Changes in 

Account Balances by Participating in the 2009 OVDP 51

Figure 7: Locations of Offshore Accounts as Disclosed in a Sample 

of 30 2009 OVDP Cases with Penalties of $1 Million or 

Greater 57

Figure 8: Bank Names of Offshore Accounts as Reported in a 

Sample of 30 2009 OVDP Cases with Penalties of $1 

Million or Greater 58
Page iv GAO-13-318 Offshore Tax Evasion

Abbreviations 

AGI Adjusted Gross Income

CDW Compliance Data Warehouse

CI Criminal Investigation 

CIMIS Criminal Investigation Management Information System

DOJ Department of Justice

EIN Employer Identification Number

ERIS Enforcement Revenue Information System

FATCA Foreign Account Tax Compliance Act

FBAR Report of Foreign Bank and Financial Accounts

FinCEN Financial Crimes Enforcement Network

IRS Internal Revenue Service

NAICS North American Industry Classification System 

OVDP Offshore Voluntary Disclosure Program

PAIR Planning, Analysis, Inventory and Research

PFIC Passive Foreign Investment Company

SOI Statistics of Income

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Page 1 GAO-13-318 Offshore Tax Evasion

United States Government Accountability Office 

Washington, DC 20548

March 27, 2013

The Honorable Max Baucus

Chairman

The Honorable Orrin G. Hatch 

Ranking Member 

Committee on Finance

United States Senate

The Honorable Dave Camp

Chairman

Committee on Ways and Means

House of Representatives

By law, U.S. citizens are required to report worldwide income from all 

sources, including income from offshore accounts.1 While taxpayers can 

hold offshore accounts for a number of legitimate reasons, some use 

them to illegally reduce their tax liabilities, often by not reporting the 

income earned on these accounts. There is no precise estimate of how 

much money the U.S. Treasury loses due to unreported income from 

offshore accounts. Former Internal Revenue Service (IRS) Commissioner 

Charles O. Rossotti said at a congressional hearing in 2002 that he 

believed offshore noncompliance to be several tens of billions of dollars, 

but did not have a precise number.2 IRS has been limited in its ability to 

uncover and pursue taxpayers with unreported offshore accounts by 

traditional means, in part because the reporting requirements that apply 

to domestic financial institutions do not generally apply to foreign 

institutions.3

Since 2003, IRS has carried out four offshore voluntary disclosure 

programs, collectively referred to in this report as “offshore programs,” 

 

1

For purposes of this report, offshore refers to any foreign jurisdiction outside of the United 

States. 

2

U.S. Senate Committee on Finance, “Schemes, Scams and Cons: The IRS Strikes 

Back,” hearing on April 11, 2002.

3

U.S. financial institutions are required to report account earnings to IRS. For years, IRS 

has compared this information to the information taxpayers report on their tax returns to 

ensure accuracy. 

 
 

Page 2 GAO-13-318 Offshore Tax Evasion

that offer incentives for taxpayers to disclose their offshore accounts and 

pay delinquent taxes, interest, and penalties.4

Some taxpayers with unreported foreign accounts may have chosen not 

to participate in one of IRS’s offshore programs, and attempted to 

circumvent some taxes, interest, and penalties owed. One technique, 

which IRS calls a “quiet disclosure,” is to file amended tax returns that 

report offshore income from prior years. Another technique is for 

taxpayers to declare existing offshore accounts for the first time with their 

current year’s tax return, but not amend prior year returns. If successful, 

these techniques result in lost revenue for the Treasury, and undermine 

the offshore programs’ fairness and effectiveness.

Generally, the programs 

offered somewhat reduced penalties and no risk of criminal prosecution if 

eligible taxpayers fully disclosed their previously unreported offshore 

accounts and paid taxes due plus interest. As of December 2012, these 

offshore programs have resulted in more than 39,000 disclosures and 

over $5.5 billion in revenues.

You asked us to review IRS’s 2009 Offshore Voluntary Disclosure 

Program (OVDP)—IRS’s second offshore program and the most recent 

program with enough closed cases for analysis. In this report we (1) 

describe the nature of the noncompliance of taxpayers participating in the 

2009 OVDP, (2) determine the extent to which IRS used data from the 

2009 OVDP in order to better prevent and detect future noncompliance, 

and (3) assess IRS’s efforts to identify taxpayers who may have 

attempted quiet disclosures or other ways of circumventing some of the 

taxes, interest, and penalties that would otherwise be owed.

To describe the characteristics of the population of taxpayers participating 

in the 2009 OVDP, we analyzed six years of tax return data from all 

participants. To get additional information about taxpayers with large 

offshore accounts, we analyzed IRS’s case files from a random sample of 

closed 2009 OVDP cases with penalties of $1 million or greater. To 

determine the extent to which IRS used data from the 2009 OVDP to 

better prevent and detect future noncompliance, we reviewed changes 

that IRS made to subsequent offshore programs. We also interviewed 

IRS officials from the Offshore Compliance Initiative office about actions 

 

4

The first three programs occurred in 2003, 2009, and 2011. The fourth program, which 

started in 2012, remains open. 
 

Page 3 GAO-13-318 Offshore Tax Evasion

taken to identify and target additional offshore noncompliance. To assess 

IRS’s efforts to detect quiet disclosures, we used IRS tax return data from 

the tax years covered by the 2009 OVDP, tax year 2003 through tax year 

2008, to identify potential quiet disclosures and compared our results with 

those from IRS. We also used tax return data from tax year 2003 through 

tax year 2010 from IRS and Report of Foreign Bank and Financial 

Accounts (FBAR) data from the Financial Crimes Enforcement Network 

(FinCEN) to assess other ways taxpayers may be circumventing some of 

the taxes, interest, and penalties owed.

5

We conducted this performance audit from June 2011 to March 2013 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

For the purposes of this review, 

we determined that the data used in our analyses were reliable. Our data 

reliability assessment included reviewing relevant documentation, 

conducting interviews with IRS officials knowledgeable about the data, 

and conducting electronic testing of the data to identify obvious errors or 

outliers. See appendix I for more information on our scope and 

methodology.

U.S. taxpayers can hold offshore accounts for a number of non-tax 

reasons, including access to funds while living or working overseas, asset 

protection, investment portfolio diversification, enhanced investment 

opportunities, and to facilitate international business transactions. U.S. 

 

5

FinCEN is a bureau of the U.S. Department of the Treasury. FinCEN’s mission is to 

enhance the integrity of the financial systems by facilitating the detection and deterrence 

of financial crime. FinCEN carries out its mission by receiving and maintaining financial 

transactions data; analyzing and disseminating that data for law enforcement purposes 

and building global cooperation with counterpart organizations in other countries and with 

international bodies. The Bank Secrecy Act requires that U.S. taxpayers file FBARs if they 

have a financial interest in or signature authority over offshore accounts with an aggregate 

value exceeding $10,000, a threshold set by the Secretary of the Treasury. 31 U.S.C. 

§ 5314; 31 C.F.R. § 1010.350.

Background

Reporting Requirements 

for Offshore Accounts
 

Page 4 GAO-13-318 Offshore Tax Evasion

taxpayers must report whether they have offshore accounts on Schedule 

B of IRS Form 1040 and pay taxes on income from the offshore accounts 

at their individual tax rates. Some taxpayers with large offshore account 

balances are also required to report additional account information, such 

as the name and location of their bank, by filing a form TD F 90-22.1, 

Report of Foreign Bank and Financial Accounts (FBAR). Failure to report 

the existence of offshore accounts or pay taxes on these accounts can 

lead to civil and criminal penalties.

U.S. financial institutions are required to submit to IRS information returns 

that report income earned by account holders.6 IRS uses the information 

to check whether taxpayers are reporting investment earnings and other 

income correctly. Unlike the reporting requirements for U.S. financial 

institutions, there has been no reporting regime for foreign financial 

institutions, and this lack of information has limited IRS’s ability to ensure 

taxpayers were reporting offshore income accurately (see fig. 1). IRS has 

begun implementing provisions of the Foreign Account Tax Compliance 

Act (FATCA), which requires, beginning in 2015, U.S. financial institutions 

to withhold a portion of certain payments made to foreign financial 

institutions that have not entered into a specific agreement with IRS to 

report information on their U.S. clients.7

 

6

26 U.S.C. § 6049. An information return is a return filed with the IRS by a person or other 

entity to report some economic information other than the tax liability of the filing person or 

entity. 

It is expected that IRS will use 

this information to identify noncompliant taxpayers. While IRS officials do 

not anticipate that FATCA will replace the offshore programs, they do 

believe that future programs may shift in focus to identifying promoters of 

offshore tax schemes that are not associated with the financial institutions 

that will be subject to FATCA reporting requirements.

7

Subtitle A of title V of the Hiring Incentives to Restore Employment Act is commonly 

referred to as FATCA. Pub. L. No. 111-147, 124 Stat. 71, 97–117 (2010). We issued a 

report on IRS’s implementation of FATCA in April 2012. See GAO, Foreign Account 

Reporting Requirements: IRS Needs to Further Develop Risk, Compliance, and Cost 

Plans, GAO-12-484 (Washington, D.C.: April 16, 2012).
 

Page 5 GAO-13-318 Offshore Tax Evasion

Figure 1: Illustration of Taxpayer and Information Reporting on Offshore Accounts

a

Different thresholds apply based on whether a filer files a joint income tax return or resides outside 

the United States, and whether asset values exceed a certain threshold at any point during the year. 

If the end of year aggregate value filing threshold is not met, a higher threshold applies during the 

year. 26 U.S.C. § 6038D; 26 C.F.R. § 1.6038D-0T to 1.6038D-8T.

b

FATCA stands for the Foreign Account Tax Compliance Act. 

IRS’s offshore programs were designed to encourage taxpayers with 

undisclosed income from offshore accounts to become current with their 

tax liabilities. Although the offshore programs differed in details, all four 

followed a cycle similar to the one illustrated in figure 2. The offshore 

programs fit into IRS’s larger compliance efforts, which are intended to 

Key Features of IRS’s 

Offshore Programs
 

Page 6 GAO-13-318 Offshore Tax Evasion

both detect noncompliance and to encourage voluntary compliance, in 

part by minimizing the burden for taxpayers to understand their tax 

obligations and file tax returns every year.

Figure 2: IRS Process for Developing Offshore Disclosure Programs

While open and intended to attract all noncompliant taxpayers with 

offshore accounts, the four offshore programs to date all started with IRS 

identifying a particular group of taxpayers suspected of having unreported 

offshore accounts. The group might be account holders at a particular 

Step 1: Identifying a Population 

of Taxpayers with Suspected 

Offshore Account 

Noncompliance
 

Page 7 GAO-13-318 Offshore Tax Evasion

bank or in a particular country. Sometimes IRS obtains such information 

from whistleblowers.8 In 2007, a whistleblower provided details to the 

U.S. government about how his employer, Swiss bank UBS, was actively 

assisting and facilitating U.S. taxpayers’ concealment of taxable income.9

The next step is to learn the identities of some of the taxpayers suspected 

of noncompliance. One technique is to use John Doe summonses.

(See app. II for more information on the UBS whistleblower.) IRS may 

also use information gathered through prior offshore programs to identify 

other banks or countries where U.S. taxpayers may be hiding offshore 

income.

10

In order to encourage program participation, IRS publicizes the fact that it 

knows, or soon will know, the names of some offshore account holders. 

IRS also publicizes the terms of its offshore programs, which offer 

incentives to taxpayers who voluntarily disclose their accounts before IRS 

learns about them. As described later, the offshore programs offer a 

reduced risk of criminal prosecution, and lower penalties than taxpayers 

could receive if unreported offshore accounts were discovered in an audit. 

In this report we refer to the reduced penalty offered as part of an 

In 

2008, prior to the announcement of the 2009 OVDP, a federal court 

granted IRS permission to serve a John Doe summons to UBS for 

information on its U.S. customers. As a result of the summons, and 

subsequent government negotiation and agreement, UBS turned over 

information on approximately 4,450 accounts held in Switzerland by U.S. 

persons. This was a partial list of all U.S. UBS account holders with 

accounts in Switzerland. In other cases, IRS has been able to get client 

lists from promoters of offshore tax evasion schemes.

 

8

The Internal Revenue Code provides whistleblowers with a significant financial incentive 

to report noncompliance. It provides for awards up to 30 percent of the collected proceeds 

that arise from the whistleblower’s information. 26 U.S.C. § 7623. 

9

Although not publicly confirmed by IRS, attorneys for the UBS whistleblower reported that 

he was awarded $104 million.

10A John Doe summons is a court ordered summons that allows IRS to seek information 

about all taxpayers in a certain group, such as those with accounts at a certain financial 

institution, without knowing individual identities beforehand. The law authorizing a John 

Doe summons requires IRS to establish in a federal court proceeding that the summons 

relates to the investigation of a particular person or ascertainable group or class of 

persons; there is a reasonable basis to believe that the targeted person or group may fail 

or may have failed to comply with tax laws; and that the information is not readily available 

from other sources. 26 U.S.C. § 7609(f).

Step 2: Identifying Some 

Specific Individuals from the 

Step 1 Population

Step 3: Publicizing Steps 1 and 

2 and Offering an Offshore 

Disclosure Program
 

Page 8 GAO-13-318 Offshore Tax Evasion

offshore program as the “offshore penalty.” In the 2009 OVDP the 

offshore penalty was typically 20 percent of the highest aggregate value 

of the unreported offshore accounts between 2003 and 2008.

Provided that they meet certain criteria, taxpayers are accepted into one 

of IRS’s offshore programs by responding to IRS questions about the 

nature of their offshore noncompliance in an application letter and filing 

amended or late tax returns and FBARs.11

Taxpayers who did not participate in an offshore program but are known 

to IRS (perhaps because they were on the list of names IRS identified in 

Step 2) run the risk of being audited outside of an offshore program. 

These taxpayers could be subject to substantially greater penalties and 

increased risk of criminal prosecution. Since 2009, IRS and the 

Department of Justice (DOJ) have publicized more than 40 prosecutions 

of UBS clients and UBS bankers.

(See app. III for sample 

application letters.) Investigators from IRS’s Criminal Investigation 

division generally review applications to verify that taxpayers are not 

already under investigation, that the offshore income was from legal 

sources, and that the taxpayer has made a complete and truthful 

disclosure. Taxpayers’ amended or late returns that are submitted as part 

of an offshore program are reviewed and certified by IRS examiners who 

calculate the delinquent taxes, interest, and penalties, and who may 

request additional documents and information from taxpayers.

Through data mining, or analyzing, information from offshore program 

application letters, and reviewing the case files of program participants 

and auditing nonparticipants, IRS is able to identify new groups of 

taxpayers suspected of hiding income offshore. IRS can then choose to 

continue offering offshore programs and encourage these newly identified 

groups of taxpayers, as well as all taxpayers with unreported offshore 

accounts, to disclose their accounts voluntarily, repeating the cycle

illustrated in figure 2. For example, taxpayers that participated in the 2009 

OVDP named other Swiss banks and financial advisors who had assisted 

them with hiding offshore income. As a result, IRS and DOJ took actions 

to compel other Swiss banks to name their U.S. customers. To date, 

some Swiss banks have announced that they are cooperating with U.S. 

 

11In the 2009 OVDP, the application letter was optional, and taxpayers could provide 

alternate documentation containing similar information; the letter was required for 

subsequent programs. 

Step 4: Review Case Files of 

Offshore Program Participants 

and Audit Nonparticipants

Step 5: Data Mining 

Information Collected in Step 4
 

Page 9 GAO-13-318 Offshore Tax Evasion

government investigations. One Swiss bank ceased operating after it 

pleaded guilty to helping U.S. taxpayers hide income offshore and agreed 

to pay approximately $74 million in fines, restitution, and civil forfeiture. 

IRS and DOJ are also pursuing other banks in Liechtenstein, Israel, and 

India, which had been named by 2009 OVDP participants.

Each of IRS’s four offshore programs had a slightly different structure, 

including a higher standard offshore penalty rate for each subsequent 

program, as shown in table 1. In the 2009 OVDP, the standard offshore 

penalty was 20 percent. The offshore programs offer participating 

taxpayers a lower penalty than they could have been subject to if IRS had 

discovered their offshore account outside of the program. According to 

IRS, the offshore penalty is in lieu of all other liabilities for tax, interest, 

and penalties that IRS would not pursue. Taxpayers that do not 

participate in an offshore program could potentially face penalties that 

total more than 100 percent of the value of their unreported offshore 

accounts. These penalties could include FBAR, accuracy-related and/or 

delinquency, fraud, and foreign information return penalties.12

Most of the offshore programs also offered taxpayers mitigated penalties 

at lower rates, generally for taxpayers with small accounts or accounts 

that were not accessed, also shown in table 1.

Many offshore accounts were presumably open for decades, something 

that we confirmed in our review of 2009 OVDP cases, but practical 

reasons prevented IRS from auditing and collecting unpaid taxes from all 

of those years. The standard 2009 OVDP 20 percent offshore penalty 

was calculated based not on additional taxes assessed, but on the 

highest aggregate value of the offshore accounts. As a result, the penalty 

has been described by tax practitioners as “rough justice,” in part 

because the amount in an account might include decades of tax-free 

buildup. (See app. IV for hypothetical examples illustrating tax-free build 

up and penalties for accounts of different ages.)

 

12A taxpayer who willfully fails to properly file an FBAR may be subject to a penalty equal 

to the greater of $100,000 or 50 percent of the balance in the account at the time of the 

violation, for each year of violation. Willful violations may also be subject to criminal 

penalties. For a full list of potential penalties for taxpayers with unreported offshore 

accounts or activities who do not participate in an offshore program see Internal Revenue 

Service, “Voluntary Disclosure: Questions and Answers,” accessed March 13, 2013, 

http://www.irs.gov/uac/Voluntary-Disclosure:-Questions-and-Answers, Q15. 

Terms of IRS’s Offshore 

Programs
 

Page 10 GAO-13-318 Offshore Tax Evasion

Under the 2003, 2009, and 2011 programs, taxpayers had a specified

period of time to join a program. The 2012 program is, at present, open 

ended. In each program, delinquent taxes and interest were assessed 

and collected for a limited number of prior years, which varied from four to 

eight tax years. Taxpayers were typically assessed accuracy-related 

and/or delinquency penalties for the delinquent taxes assessed in an 

offshore program, in addition to the offshore penalty described earlier.

Table 1: Comparison of IRS’s Offshore Voluntary Disclosure Programs 

2003 Offshore 

Voluntary Compliance 

Initiative

2009 Offshore 

Voluntary Disclosure 

Program

2011 Offshore 

Voluntary Disclosure 

Initiative

2012 Offshore 

Voluntary Disclosure 

Program

Factors that influenced 

participation

Promoters identified and 

John Doe summons for 

information on taxpayers 

who used bank cards to 

access hidden offshore 

income

John Doe summons for 

UBS accounts in 

Switzerland

IRS actions against many 

foreign banks, including 

HSBC, which provided 

IRS information on 

accounts in India 

FATCA and increased 

actions against a number 

of foreign financial 

institutions

Application period January 14, 2003, to 

April 15, 2003

March 23, 2009, to 

October 15, 2009a February 8, 2011, to 

September 9, 2011

January 9, 2012, to 

presentb

Tax years for which 

delinquent taxes were 

collected

4 years 

(1999 to 2002)

6 years 

(2003 to 2008)

8 years

(2003 to 2010)

8 yearsc

Standard offshore 

penalty rated

 

No offshore penalty 20% 25% 27.5%

Mitigated offshore 

penalty rate 

No offshore penalty 5% for passive account 

holders.e

Beginning in February

2011, 2009 OVDP 

participants could receive 

2011 OVDI mitigated 

penalties, which they 

were allowed to apply for 

retroactively. 

12.5% for accounts 

valued less than 

$75,000.

5% for passive account 

holders.e

 

12.5% for accounts 

valued less than 

$75,000.

5% for passive account 

holders.e

Other penalties Accuracy-related penalty (up to 20% of unpaid taxes) and/or 

Delinquency penalty (up to 25% of unpaid taxes)

IRS reported number of

disclosures

1,321 15,000 18,000 Approximately 5,000 to

date

Total collected (unpaid 

taxes, penalties and/or 

fees) as reported by IRS

$200 million $4.1 billion

(as of December 31, 

2012)

$1.4 billion 

(as of December 31, 

2012

Not available

Source: GAO analysis of IRS offshore voluntary disclosure program information.

a

The IRS granted a one-time extension of the original September 23, 2009, deadline for certain 

voluntary disclosures. Those taxpayers had until October 15, 2009. 

b

The 2012 OVDP has no set deadline for taxpayers to apply. Additionally, IRS stated that the terms of 

the program could change at any time. For example, IRS could increase penalties associated with the 
 

Page 11 GAO-13-318 Offshore Tax Evasion

program for all or some taxpayers or a defined class of taxpayers, or decide to end the program at 

any point. 

c

Tax years covered are determined by the last closed tax year when the taxpayers apply to the 

program, plus the seven previous tax years. 

d

The offshore penalty rate is applied to the highest aggregate account balance during the calendar 

years that correspond to the tax years covered by the program. 

e

A 5 percent penalty rate was generally allowed if taxpayers did not open or cause the account to be 

opened, had no account use, and had paid all applicable U.S. taxes on funds deposited to the 

accounts, with only account earnings having escaped U.S. taxation. In later program years, minimal 

account activity was allowed, for example, to update address information, or to withdraw a minimal 

amounts of funds, defined as less than $1,000 in any program year for which the taxpayers was 

noncompliant. This limit did not include transfers back to the United States upon closing an offshore 

account. 

Despite the significant risks of not coming forward through one of IRS’s 

offshore programs, some taxpayers decide to do nothing and remain 

noncompliant. Other taxpayers have attempted to disclose their offshore 

accounts without paying all the delinquent taxes, interest, and penalties 

required by the programs. In a quiet disclosure, taxpayers file amended 

tax returns for all or some of the tax years covered by an offshore 

program, and report the income from the previously unreported accounts. 

The taxpayers would generally pay interest and either accuracy-related or 

delinquency penalties on the newly reported income, but would avoid the 

higher offshore penalty.13

 

13The offshore penalty is not a penalty established by statute that taxpayers with 

undisclosed foreign accounts are required to pay by law. It is an amount voluntary 

participants in the offshore programs agree to pay in exchange for the benefits associated 

with participation in those programs, and its collection is authorized by the IRS’s 

settlement authority conferred in IRC sections 7121 and 7122.

At the same time, taxpayers attempting quiet 

disclosures would file late FBARs, if they had not previously filed FBARs, 

or amended FBARs, if they had, to disclose the offshore accounts that 

they had not previously reported. Taxpayers might also try to circumvent 

some of the taxes, interest, and penalties that would otherwise be owed 

in offshore programs by reporting the existence of any offshore accounts 

and any income from the accounts on their current year’s tax return, 

without amending prior years’ returns. These taxpayers would also likely 

disclose the existence of the accounts by filing FBARs for the current 

calendar year. This filing would appear similar to the opening of a new 

account. Such a taxpayer would avoid paying any delinquent taxes, 

interest, or penalties, unless audited. As described earlier, taxpayers who 

are caught disclosing offshore accounts outside of one of IRS’s offshore 

programs risk steeper penalties and criminal prosecution, based on the 

facts and circumstances of their cases.

Attempts to Circumvent 

Some of the Taxes, 

Interest, and Penalties that 

Otherwise Would Be Owed 

in Offshore Programs
 

Page 12 GAO-13-318 Offshore Tax Evasion

Participants in IRS’s 2009 OVDP had offshore accounts that varied 

considerably in size. Of the 10,439 closed 2009 OVDP cases, we 

estimate based on penalty data that the bottom 10 percent of the 

participants had account balances of less than $79,000 and the top 10 

percent had balances over $4 million, as shown in table 2.14

 

14We identified 19,337 total participants in IRS’s 2009 OVDP. Those participants had 

10,439 closed cases, as of November 29, 2012, that we could analyze. The 19,337 

participants we identified as participating in IRS’s 2009 OVDP differs from the number 

released publicly by IRS, which has been 15,000. The number released publicly by IRS 

reflects the total applicants accepted into OVDP by CI, while our figure represents the total 

number of taxpayers reviewed within the 2009 OVDP civil penalty structure, meaning that 

we added some spouses and other taxpayers that were assessed offshore penalties. See 

appendix I for more information on our methodology. Of the 19,337 participants that we 

identified, 200 (or 1 percent) were businesses. See appendix V for characteristics of these 

businesses. 

The amount 

of offshore penalties also varied widely, which reflected the range of 

account balances. Some taxpayers were assessed an offshore penalty of 

a few thousand dollars while others were assessed several million dollars. 

The average offshore penalty assessed was about $376,000 while the 

median was approximately $108,000.

Almost All 2009 OVDP 

Participants Received 

the Maximum 

Offshore Penalty, 

Almost Half Had 

Accounts in 

Switzerland, and 

About Half of the 

Revenue Collected 

Came from a Small 

Percentage of High 

Penalty Cases

Summary of All 2009 

OVDP Closed Cases
 

Page 13 GAO-13-318 Offshore Tax Evasion

Table 2: Selected Penalty Information for 2009 OVDP Individual Taxpayers with Closed Cases as of November 29, 2012 

Mean 10th percentile 25th percentile Median 75th percentile 90th percentile

Offshore account(s) balancea $1,923,310 $78,315 $190,365 $568,735 $1,595,805 $4,054,505

2009 OVDP penalty 375,879 13,320 35,670 107,949 310,476 793,166

Additional tax owed, 

tax years 2003-2008

97,681 103 1,661 12,748 60,449 190,399

Interest, 

tax years 2003-2008

29,645 52 482 3,486 17,398 57,129

Other penaltiesb 24,014 84 605 3,457 14,290 45,163

Total penalties, interest 

and taxes

$433,840 $2,318 $22,120 $95,982 $330,185 $923,300

Source: GAO analysis of IRS’s Enforcement Revenue Information System (ERIS) and Individual Returns Transaction File.

Note: Totals may not equal sum of components due to variation in the component populations. 

a

2009 OVDP offshore account balance is an estimated number based on penalty amounts. It 

represents the highest aggregate balance of all offshore accounts between 2003 and 2008. 

b

Other penalties primarily included accuracy-related penalties and delinquency penalties. 

Of the 10,439 closed cases, most were assessed offshore penalties and 

96 percent of those assessed penalties received the standard offshore 

penalty—20 percent of the highest aggregate value of the offshore 

accounts, which was also the maximum offshore penalty rate in the 2009 

OVDP. The 20 percent penalty was generally levied when the total 

account value was greater than $75,000 and when taxpayers used the 

accounts (e.g., made deposits or withdrawals) during the period under 

review (2003 to 2008). See table 3.

Table 3: Type and Amount of Offshore Penalties for 2009 OVDP Closed Cases 

(Individual Taxpayers) as of November 29, 2012

Percent of closed 

cases with penalties

Total penalty 

dollars

Median penalty 

amount

20 percent penalty 96 $2.786 billion $116,393 

12.5 percent penalty less than 1 0.002 billion 5,831 

5 percent penalty 4 0.021 billion 18,478 

All penalty rates $2.810 billion $107,949

Source: GAO analysis of IRS’s ERIS.

Note: Total for penalty dollars may not equal sum of components due to rounding. 
 

Page 14 GAO-13-318 Offshore Tax Evasion

Fewer than 5 percent of 2009 OVDP participants received one of the 

mitigated offshore penalties, 12.5 percent or 5 percent, also shown in 

table 3. (See sidebars for representative examples of mitigated penalty 

cases.) 

Consistent with IRS’s enforcements efforts and the design of the 2009 

OVDP, we found that the population of participants was more likely to 

report offshore accounts in Switzerland than the average foreign account 

holder who filed an FBAR (see fig. 3). Taxpayers with closed cases also 

had higher incomes than the average taxpayer, were older, and were 

more likely to use the married filing jointly status. (See app. VI.)

Figure 3: Top Ten Locations of Offshore Accounts on 2008 FBARs Filed by 2009 

OVDP Participants Compared to All 2008 Individual FBAR Filers
 

Page 15 GAO-13-318 Offshore Tax Evasion

Note: OVDP stands for Offshore Voluntary Disclosure Program and FBAR stands for Report of 

Foreign Bank and Financial Accounts. 

About half of the revenues collected through the 2009 OVDP, as of March 

30, 2012, came from 378 cases where taxpayers received offshore 

penalties of $1 million or greater, meaning they had account balances of 

$5 million or greater. This group, which we refer to as “large penalty 

cases”, accounted for about 6 percent of the closed 2009 OVDP cases, 

but the penalties they received amounted to 49 percent of the total $1.9 

billion in offshore penalties that had been assessed by IRS at that time.15

For large penalty cases, we estimate that more than 50 percent of 

taxpayers had one or more bank accounts with Swiss bank UBS.

Given this group’s high share of penalties assessed, we selected a 

random sample of 30 of them for further examination and to obtain a 

better understanding taxpayers’ noncompliance.

16

 

15Throughout the rest of our report, we use an updated November 29, 2012, figure. As of 

that date, 56 percent of the total $2.8 billion in offshore penalties assessed were from 

cases with penalties of $1 million or greater. 

 (See 

app. VII for detailed information on the location of these taxpayer’s 

offshore accounts, including country and bank names.) Some of these 

taxpayers with UBS accounts transferred funds from Swiss bank UBS in 

2008—the time when the U.S. government was actively trying to compel 

UBS to name its U.S. account holders. The funds were often transferred 

to other, smaller Swiss banks that generally did not operate in the United 

States. A few taxpayers claimed that they transferred funds at the 

recommendation of their UBS financial advisors. Taxpayers transferring 

funds to other banks may have been attempting to keep their offshore 

accounts hidden before deciding to participate in the 2009 OVDP.

16The 95 percent confidence interval for the estimated 70 percent of taxpayers receiving 

large penalties with accounts at Swiss bank UBS is 51 percent to 85 percent. See 

appendix I for more information on our scope and methodology and appendix VII for more 

counts by case file.

Results from Sample of 

Large Penalty Cases

More than Half of Taxpayers 

Receiving Large Penalties Had 

Accounts at Swiss Bank UBS 

and Some First Transferred 

Funds from UBS to Other Swiss 

Banks before Entering the 2009 

OVDP
 

Page 16 GAO-13-318 Offshore Tax Evasion

Many taxpayers in the 30 large penalty cases that we reviewed had 

resided outside the United States for extended periods of time—either as 

U.S. citizens or prior to obtaining U.S. citizenship.17

Taxpayers in some of the cases that we reviewed disclosed that the 

original source of funds for their offshore accounts came from post-tax 

U.S. source income. A few of these taxpayers cited family histories or 

personal fears about the safety of U.S. banks as their reasons for moving 

savings offshore. Others reasons cited included the need to protect or 

shelter assets from possible U.S. lawsuits.

Many taxpayers who 

disclosed extended periods of non-U.S. residency reported that they had 

opened their offshore accounts with income earned outside of the United 

States. A few of these taxpayers had been living and working overseas as 

U.S. citizens for decades. Others within this group opened accounts 

before immigrating to the United States. Although some taxpayers in 

these cases became U.S. residents decades ago, they maintained their 

offshore accounts and did not disclose them on tax returns or FBARs. 

Some taxpayers reported opening bank accounts in Switzerland as a 

means of protecting family assets during periods of war or instability in 

their native country. Further, a few taxpayers who immigrated to the 

United States reported that they had been unaware of their FBAR 

reporting requirements, that they had to state that they had foreign 

accounts on the Form 1040, Schedule B, or that the United States taxes 

the worldwide income of its residents, including overseas investment 

income. (See sidebars for representative examples from our case file 

reviews.) 

We estimate that 47 percent of taxpayers receiving large penalties 

inherited offshore accounts from a parent, spouse, or other relative—

some of whom were not U.S. citizens or residents.18

 

17Under the U.S. worldwide tax system, U.S. citizens and residents generally must report 

income, wherever it is earned, including income from foreign bank accounts, to the IRS. 

In many instances, 

taxpayers reported inherited accounts that were jointly owned or 

managed by extended family members, such as siblings and cousins, 

who also applied to the 2009 OVDP and sometimes split the penalties. 

Regardless of how taxpayers in the large penalty cases came to own 

offshore accounts, many maintained but did not disclose offshore account 

18The 95 percent confidence interval for the estimated 47 percent of taxpayers receiving 

large penalties who inherited offshore accounts is 29 percent to 65 percent.

Taxpayers Receiving Large 

Penalties Disclosed a Variety of 

Reasons for Having Offshore 

Accounts
 

Page 17 GAO-13-318 Offshore Tax Evasion

balances of several million dollars for many years. Some of these 

taxpayers did not pay U.S. taxes on income earned from these accounts 

for decades.

We estimate that 40 percent of 2009 OVDP participants receiving large 

penalties used complex arrangements to indirectly own or manage their 

offshore accounts.19 These arrangements involved the use of foreign 

corporations, foundations, trusts, and other entities in jurisdictions that 

have been designated as offshore tax havens and financial privacy 

jurisdictions, some of which were recommended by the taxpayers’ foreign 

financial advisors.20 In some cases, the entities were “sham” entities—i.e., 

entities created to conceal ownership from U.S. tax authorities—which 

participants in some case files that we reviewed used to conceal the 

ownership of accounts or disguise the repatriation of offshore funds back 

to the United States. Another complex arrangement present in several 

large penalty cases was passive foreign investment companies (PFIC). A 

PFIC is a type of mutual fund or investment company held outside of the 

United States.21 Some foreign bank accounts disclosed through OVDP 

were in the form of simple interest bearing accounts, but others were 

foreign mutual funds that would be treated as PFICs under the Internal 

Revenue Code. PFICs may, in some cases, receive less favorable tax 

treatment than U.S. entities holding similar assets or earning similar 

income.22

 

19The 95 percent confidence interval for the estimated 40 percent of taxpayers disclosing 

the use of complex arrangements to indirectly own or manage their offshore accounts 

ranged from 23 percent to 59 percent. 

Taxpayers who did not disclose PFICs may not have paid the 

additional taxes on such investments. In many cases, a number of 

previously unreported investment entities were disclosed through the 

20For a list of tax havens and financial privacy jurisdictions sourced to the Organization for 

Economic Co-operation and Development, the National Bureau of Economic Research 

and a U.S. District Court order granting leave for IRS to serve a John Doe summons, see 

Table 1 in GAO, International Taxation: Large U.S. Corporations and Federal Contractors 

with Subsidiaries in Jurisdictions Listed as Tax Havens or Financial Privacy Jurisdictions,

GAO-09-157 (Washington, D.C.: Dec. 18, 2008). 

21Generally, a foreign corporation is considered to be a PFIC if certain percentages of the 

corporation’s income or assets are passive. 26 U.S.C. § 1297.

22Joint Committee on Taxation, General Explanation of the Tax Reform Act of 1986, JCS10-87, May 4, 1987. Also see GAO, Cayman Islands: Review of Cayman Islands and U.S. 

Laws Applicable to U.S. Persons’ Financial Activity in the Cayman Islands, 

GAO-08-1028SP an E-supplement to GAO-08-778 (Washington, D.C.: July 24, 2008).
 

Page 18 GAO-13-318 Offshore Tax Evasion

2009 OVDP, and IRS decided to accept an alternative tax on all their 

associated PFIC gains—20 percent of the gain—potentially a much lower 

tax rate than would otherwise have been available to those taxpayers. 

As previously discussed, one of the intended purposes of the 2009 OVDP 

was mining, or analyzing, data collected from OVDP applications and 

audits of participants and nonparticipants to identify entities and 

individuals who promoted or otherwise helped U.S. citizens hide assets 

and income offshore.23

IRS officials from the Offshore Compliance Initiative office told us that 

publicity from the John Doe summonses has been the most effective tool 

to increase participation in its offshore programs. They based their 

conclusion on the correlation between country specific or bank specific 

John Doe summonses and the locations of 2009 OVDP participants’ 

We found that IRS collected the names of offshore 

financial institutions, financial advisors, bankers, attorneys, and other 

promoters from the 2009 OVDP that were involved in hiding U.S. 

taxpayers’ offshore income, and used the names to (1) identify patterns of 

noncompliance, (2) encourage banks and other promoters to cooperate 

with IRS and provide the names of U.S. taxpayers hiding income 

overseas, and (3) build cases for John Doe summonses.

 

23Internal Revenue Service, “FY 2011 Congressional Budget Submission,” February 1, 

2010. 

IRS Generally Has 

Used 2009 OVDP Data 

Strategically, But Has 

Not Used the Data to 

Identify Additional 

Opportunities to 

Educate Taxpayers on 

Offshore Filing 

Requirements

IRS Used 2009 OVDP Data 

to Identify Noncompliance 

Involving Additional Banks 

and Countries and to 

Improve Subsequent 

Offshore Voluntary 

Disclosure Programs
 

Page 19 GAO-13-318 Offshore Tax Evasion

accounts. Our case file analysis discussed previously in this report 

supports IRS’s conclusion.

However, IRS officials also determined that data mining the 2009 OVDP 

applications would not provide IRS with all of the useful information it 

could get from participants. For taxpayers accepted into the program, 

responses on the 2009 OVDP applications varied widely in degree of 

detail, which we confirmed in our case file review. For example, some 

application letters included very detailed account information, such as the 

original source of funds, bank name, banker name, and country name, 

while other case files we reviewed did not contain any optional letter like 

the one suggested by IRS in its 2009 OVDP Questions & Answers. As a 

consequence, IRS sent surveys to 2009 OVDP participants to obtain 

more details about the offshore accounts. The survey included detailed 

questions about the taxpayer’s financial institutions, bankers, advisors, 

attorneys, or other promoters’ involvement in hiding offshore income. IRS 

program officials stated that the additional information they received from 

the surveys was useful and that they were using it, along with various 

analyses of voluntary disclosures, to identify particular banks, promoters, 

professionals, and others who promote, facilitate, or enable U.S. 

taxpayers in avoiding or evading payment of required U.S. taxes through 

the use of offshore accounts. According to IRS, these analyses have also 

been used to identify the foreign countries where the offshore accounts 

were maintained as well as the schemes being used and offshore 

structures.

Based on data that IRS collected from mining the 2009 OVDP case files 

and the survey, IRS

• obtained information on offshore accounts held by U.S. taxpayers at 

HSBC (India);

• continued investigations of additional foreign financial institutions in 

Switzerland, Asia, and the Caribbean;

• built cases for additional John Doe summonses, should they become 

necessary;

• expanded its investigations of non-bank entities, such as merchant 

accounts, which are a type of bank account that allows a business to 
 

Page 20 GAO-13-318 Offshore Tax Evasion

accept payments by payment cards, such as credit or debit cards;24

• improved subsequent offshore programs.

and

One lesson that IRS learned from the 2009 OVDP was that the 

applications sometimes did not contain enough information to allow IRS 

to understand the nature of the noncompliance. To obtain better 

information going forward, and as a condition of being accepted into the 

2011 and 2012 programs, IRS required applicants to submit additional 

documents related to their offshore accounts.25

Based in part on its experience with the 2009 OVDP, IRS introduced 

streamlined offshore program filing procedures. These were, in part, 

intended to provide a less burdensome process for taxpayers with 

unreported offshore accounts that were small. As shown earlier in table 2, 

for the 10,439 2009 OVDP cases that we had data for, the account value 

for the 10th percentile was about $78,000. According to IRS, some of 

these taxpayers with smaller accounts, and thus relatively low unpaid-tax 

obligations, were U.S. residents residing overseas, including dual 

citizens, who most likely did not owe substantial amounts of unpaid taxes, 

and who indicated to IRS that they did not understand their filing 

requirements. The standard offshore penalty for such taxpayers would 

likely be disproportionately high. The streamlined filing procedures that 

This included additional 

account information about the original source of funds. In addition, 

applicants to the 2011 and 2012 programs that had offshore accounts 

with an aggregate balance of $1 million or more were required to submit a 

separate statement for each foreign financial institution. These applicants 

were also required to submit a separate statement for each foreign 

account or asset listed in their voluntary disclosure. (See app. III for 

sample 2009 and 2012 application letters and, the new required 

attachment to the 2012 application letter.) IRS officials from the Offshore 

Compliance Initiative office told us that they have begun to use data from 

these additional submissions to improve offshore compliance.

 

24According to IRS officials, some foreign banks have facilitated U.S. taxpayers in setting 

up merchant accounts offshore, in countries other than their countries of business, to hide 

income. 

25Additional required documents can be found on IRS’s website, “Offshore Voluntary 

Disclosure Program Submission Requirements,”

http://www.irs.gov/Individuals/International-Taxpayers/Offshore-Voluntary-DisclosureProgram-Submission-Requirements, accessed February 8, 2013.
 

Page 21 GAO-13-318 Offshore Tax Evasion

began in September 2012 allow taxpayers with “low compliance risk” to 

become current with their offshore tax obligations without facing offshore 

penalties or additional enforcement action. IRS defined “low compliance 

risk” as taxpayers with simple tax returns, owing less than $1,500 in taxes 

for each of the years covered by the streamlined procedures.26

IRS efforts to publicize the 2009 OVDP included notices published in 

seven languages and outreach to professional tax practitioners. IRS 

officials from the Offshore Compliance Initiative office told us that they 

had not formally evaluated the success of these outreach efforts. We 

recently reported concerns about the complexity of foreign account 

reporting requirements, and that tax practitioners and taxpayers are 

confused about what foreign account information should be reported and 

how.27

The offshore programs are part of IRS’s larger compliance efforts, which 

are intended to both detect noncompliance and to encourage voluntary 

compliance, in part by minimizing the burden for taxpayers to understand 

their tax obligations and file tax returns every year. Obtaining information 

on how taxpayers found out about IRS’s offshore voluntary disclosure 

programs could help IRS better identify populations that could benefit 

from additional taxpayer education and outreach and potentially improve 

voluntary compliance by taxpayers with new offshore accounts. Such 

information could also help IRS evaluate the success of its current 

outreach efforts. IRS’s 2009 OVDP application, however, did not contain 

a question on how the taxpayer became aware of the program. IRS made 

changes to the applications for subsequent programs, as described 

earlier, but did not consider adding questions on how participants became 

 

26In order to use the streamlined filing procedures, taxpayers must file amended or late 

tax returns for the previous three years, and file any delinquent FBARs for the previous six

years. If taxpayers self-determine they are a low compliance risk, they can submit returns 

through these new procedures, and not through the current, ongoing offshore voluntary 

disclosure program. If IRS later determines any of these taxpayers have a higher 

compliance risk, the taxpayers are subject to a more thorough review, potentially subject 

to an audit outside of the offshore program, and subject to potentially steeper FBAR 

penalties. According to IRS officials, these new procedures will assist many U.S. 

taxpayers who are nonresident, nonfilers with relatively low additional taxes owed, and 

taxpayers with certain foreign retirement accounts.

27GAO, Reporting Foreign Accounts to IRS: Extent of Duplication Not Currently Known, 

but Requirements Can Be Clarified, GAO-12-403 (Washington, D.C.: Feb. 28, 2012). 

Despite the Successes of 

IRS’s Overall Strategy, IRS 

Might Benefit from 

Additional Information to 

Better Target Outreach and 

Education
 

Page 22 GAO-13-318 Offshore Tax Evasion

aware of the program. IRS officials from the Offshore Compliance 

Initiative office told us that this information would be useful in terms of 

allocating future resources, and that they would be open to considering a 

question on how taxpayers found out about the offshore programs. 

Presently, IRS has not decided to include this question in the 2012 

program application.

In our case file review, we found examples of immigrants who stated in 

their 2009 OVDP applications that they were unaware of their FBAR filing 

requirements. We found they had often opened banks accounts in their 

home country prior to immigrating to the United States. IRS officials from 

the Offshore Compliance Initiative office stated that although there are 

several FBAR education programs, none are specifically targeted at new 

immigrants. Furthermore, these IRS officials were unaware of any IRS 

work with other federal agencies such as the State Department or the 

Department of Homeland Security to educate recent immigrants about 

their foreign account filing requirements. These officials stated that one of 

the challenges that they face in their office, which is part of IRS’s Large 

Business and International Division, is that taxpayer education and 

outreach is the responsibility of IRS’s Wage and Investment Division and 

that issues concerning FBARs fall under IRS’s Small Business/SelfEmployed Division.

IRS officials from the Offshore Compliance Initiative office agree that 

more could be done to improve taxpayer education and outreach about 

offshore reporting requirements. They, like us, recognize that multiple 

outreach efforts could help to draw additional taxpayers into the offshore 

programs, and that data mining information from the program applications 

can help identify these groups.
 

Page 23 GAO-13-318 Offshore Tax Evasion

Quiet disclosures matter because if IRS does not identify them, it 

undermines the incentive to participate in the offshore programs. IRS’s 

offshore compliance enforcement efforts, including the offshore programs, 

deter taxpayers with noncompliance related to current offshore accounts, 

or offshore accounts that might be opened in the future. If taxpayers are 

able to quietly disclose and pay fewer penalties than they would have in 

an offshore program, the incentive for other noncompliant taxpayers to 

participate in a program is reduced. When quiet disclosures remain 

undetected, they also result in lost revenue for the government. Further, if 

quiet disclosures remain undetected, then IRS will not have information 

on the characteristics of these taxpayers and their accounts—

characteristics such as bank names, country names, and promoter 

names—used to build cases against others.

IRS May Not Be 

Identifying a Large 

Number of Quiet 

Disclosures or Other 

Attempts to 

Circumvent Some of 

the Taxes, Interest, 

and Penalties that 

would be Otherwise 

Owed by Not 

Participating in an 

Offshore Program

Taxpayer Use of Quiet 

Disclosures to Avoid 

Offshore Penalties 

Involves Significant Risk
 

Page 24 GAO-13-318 Offshore Tax Evasion

We identified 10,595 potential quiet disclosures, a number much higher 

than the potential quiet disclosures identified by IRS.28 In a series of 

Questions & Answers that IRS first released on February 8, 2011 to 

announce the 2011 offshore program, IRS reported that it had identified, 

and will continue to identify, taxpayers attempting quiet disclosures.29 In 

the Questions & Answers, IRS stated that it would be closely reviewing 

amended tax returns to determine whether enforcement action is 

appropriate. (See sidebar for one example of a quiet disclosure being 

detected.30

IRS officials told us that the Offshore Compliance Initiative office tested 

several different methodologies to identify quiet disclosures. First, IRS 

looked at amended returns during tax year 2003 to tax year 2008, the 

period covered by the 2009 OVDP, and removed any non-offshore 

related adjustments, such as filings status changes and additional 

exemptions. IRS also looked at amended returns with increased tax 

assessments over an established threshold during tax year 2003 to tax 

year 2010.

) 

The effectiveness of a third effort was questioned by IRS. In this effort 

IRS compared taxpayers with a history of filing FBARs in non-secrecy 

jurisdictions between tax year 2003 and tax year 2008 who filed 

delinquent FBARs processed in 2009 involving a secrecy jurisdiction 

along with an amended return.31

 

28Only an IRS examination can determine actual quiet disclosures and there are many 

reasons why a potential quiet disclosure may turn out to be something else. According to 

IRS, these include taxpayers who had legally paid taxes on their offshore income, but had 

not previously filed FBARs, and who were paying additional taxes with their amended 

returns for reasons unrelated to the offshore accounts and newly filed FBARs. 

29Internal Revenue Service, “2011 Offshore Voluntary Disclosure Initiative Frequently 

Asked Questions and Answers,” accessed February 5, 2013, 

http://www.irs.gov/Businesses/International-Businesses/2011-Offshore-VoluntaryDisclosure-Initiative-Frequently-Asked-Questions-and-Answers. 

30Unlike the other sidebars presented in this report, this is not drawn from an 

amalgamation of multiple cases in our case file review, but from publicly available 

information on one specific case.

31A secrecy jurisdiction refers to a jurisdiction, or country, that offers financial secrecy laws 

in an effort to attract investment from outside its borders.

IRS May Not Be Detecting 

Some Quiet Disclosures
 

Page 25 GAO-13-318 Offshore Tax Evasion

In 2012, a fourth effort, which was not designed to detect quiet 

disclosures, but to reroute misaddressed amended returns sent in by 

participants in the 2011 offshore program, was the most successful effort 

to find them.

Together, these four efforts led to the review of several thousand tax 

returns. Of those, several hundred returns were identified as quiet 

disclosures. An IRS official told us that the tax returns that were identified 

as part of a quiet disclosure will be examined and that cases already 

examined had penalties assessed. Because they were quiet disclosures, 

the official said the taxpayers did not receive the reduced offshore 

penalty.

Given the importance of IRS’s ability to detect quiet disclosures and 

evidence that they exist, we tested a different methodology to identify 

potential quiet disclosures, and found many more than IRS detected. 

Unlike IRS, we looked at all taxpayers who, for the tax years covered by 

the 2009 OVDP

• filed amended or late returns, and

• filed amended or late FBARs.

We then excluded 2009 OVDP participants from this population. While 

only an IRS examination can determine whether a potential quiet 

disclosure is an actual quiet disclosure, the 10,595 taxpayers that we 

identified have an unlikely combination of characteristics that could 

indicate that taxpayers are quietly disclosing. IRS agreed with our 

methodology as reasonable and appropriate. (See app. I for additional 

details about our methodology and app. VIII for a full breakout of our 

results.)

Although any of the 10,595 potential quiet disclosures could be actual 

quiet disclosures, certain subpopulations raised more questions. First, we 

found 3,386 taxpayers that filed amended or late returns, and filed 

amended or late FBARs for multiple years. Second, we found that 94 of 

these taxpayers met the same criteria for all six tax years covered by the 

2009 OVDP.

IRS officials from the Offshore Compliance Initiative office told us that 

they had no additional work planned to identify potential quiet disclosures 

and had not yet decided to broaden the methodologies that they had 

tested, but they expressed strong interest in researching our methodology 

to identify taxpayers attempting quiet disclosures. We recognize that 
 

Page 26 GAO-13-318 Offshore Tax Evasion

there are additional costs to using a methodology such as the one we 

used, but IRS has already committed resources to identifying quiet 

disclosures. Moreover, without rigorously and systematically searching for 

potential quiet disclosures, IRS does not have reasonable assurance that 

it is controlling such disclosures and collecting the delinquent taxes, 

interest, and penalties due. Exploring different methodologies that include 

a systematic evaluation of amended returns or late filed returns, along 

with amended or late filed FBARs, without too narrowly restricting either 

the amended return or the FBAR populations, and implementing the best 

option could provide this assurance.

Data from IRS’s SOI division and from FinCEN show that the number of 

taxpayers reporting offshore accounts on Form 1040, Schedule B and the 

number of taxpayers filing FBARs has increased significantly in recent 

years. From tax year 2007 to tax year 2010 (the most recent data 

available), IRS estimated that the number of taxpayers reporting offshore 

accounts on Form 1040, Schedule B nearly doubled to 516,000, as 

shown in figure 4. From tax year 2003 through tax year 2007, only about 

1 percent of all taxpayers filing Form 1040, Schedule B checked a “yes” 

box in response to the question asking if they owned or controlled a 

foreign financial account, but that share increased to more than 2.5 

percent by tax year 2010. Furthermore, FinCEN has reported that the 

number of FBARs filed more than doubled, as shown in figure 4. Both the 

increase in the number of foreign accounts reported on Form 1040, 

Schedule B and the increase in FBAR filings are significantly larger than 

the approximately 39,000 taxpayers that came forward in one of IRS’s 

offshore programs. 

There could be legitimate reasons for these trends. For example, 

taxpayers could be reporting new offshore accounts or taxpayers who 

had always reported income from offshore accounts on their tax returns 

could be filing FBARs and reporting the accounts on Form 1040, 

Schedule B for the first time. This could be an indication of more 

taxpayers coming into compliance as a result of IRS’s efforts to combat 

offshore tax evasion.

Increases in Taxpayers 

Reporting Offshore 

Accounts May Also 

Indicate Attempts to 

Circumvent Some Taxes, 

Interest, and Penalties that 

Would Otherwise be Owed
 

Page 27 GAO-13-318 Offshore Tax Evasion

Figure 4: Taxpayers Reporting Foreign Financial Accounts

Note: IRS Form 1040, Schedule B, Line 7a includes a yes/no question asking taxpayers if, at any 

time during the tax year, they had an interest in or a signature or other authority over a financial 

account in a foreign country, such as a bank account, securities account, or other financial account. 

The figure contains IRS estimates of the number of forms in which a taxpayer answered “yes” to this 

question. 

Under the Bank Secrecy Act, U.S. residents or citizens with a financial interest or signature authority 

over one or more foreign financial accounts with a total of more than $10,000 are required to annually 

file form TD F 90-22.1 Report of Foreign Bank and Financial Accounts (FBAR) with Treasury. The 

FBAR must be filed for the calendar year by June 30 of the following year. The figures above are the 

number of FBARs filed during a fiscal year as reported in FinCEN annual reports. 

However, such a sharp increase in foreign account reporting amidst the 

global economic recession and the publicity surrounding IRS’s offshore 

programs raises the question whether some of these taxpayers may have 

attempted to circumvent some of the taxes, interest, and penalties that 

would otherwise be owed in the offshore programs. Unlike taxpayers 

attempting a quiet disclosure, who would still pay taxes plus interest on 

previously unreported income covered by the programs, and possibly an 
 

Page 28 GAO-13-318 Offshore Tax Evasion

accuracy-related or delinquency penalty, these taxpayers would only be 

paying taxes on the offshore income earned for the year reported.32

An IRS official from the Offshore Compliance Initiative office told us that 

although the office has coordinated with IRS’s Planning, Analysis, 

Inventory, and Research (PAIR) office, they had not discussed Form 

1040, Schedule B or FBAR filing trends, and that he was not aware of the 

sharp increase. As of January 2013, no projects were planned to 

research Form 1040, Schedule B filing trends. However, the Offshore 

Compliance Initiative office has asked PAIR to determine whether 

taxpayers who reported their offshore income properly, but had not filed 

FBARs, recently started filing delinquent FBARs, as directed by the 2009 

OVDP instructions.33

Because the increase in recent years in Form 1040, Schedule B and 

FBAR reporting of foreign accounts is measured in the hundreds of 

thousands, we recognize that it may be too costly for IRS to audit all of 

those filings. A less costly approach could involve, for example, IRS 

drawing a random sample of those cases and auditing them to 

understand whether taxpayers are trying to circumvent some of the taxes, 

interest, and penalties that would otherwise be owed in the offshore 

programs. One of the things that IRS could look for in such an audit is the 

date that the offshore account was opened. Such a sample could provide 

an estimate of the magnitude of any problem. As was the case with quiet 

disclosures, without such information, it will be difficult for IRS to provide 

reasonable assurance that taxpayers are not reporting, for the first time, 

offshore accounts that had been open for years to avoid paying 

delinquent taxes, interest, and penalties.

This effort may not capture first time FBAR filers 

who are reporting existing offshore accounts as new.

Despite challenges in detecting offshore accounts, IRS’s offshore 

programs have been effective in compelling taxpayers to disclose their 

 

32In a similar situation, taxpayers might be filing the new IRS Form 8938 for offshore 

accounts that are not in fact new, without fulfilling their FBAR filing requirement, if 

applicable. IRS Form 8938 resulted from a FATCA provision requiring certain taxpayers, 

beginning in 2012, to report foreign financial accounts. 

33See Internal Revenue Service, “Voluntary Disclosure: Questions and Answers,” 

accessed February 8, 2013, http://www.irs.gov/uac/Voluntary-Disclosure:-Questions-andAnswers, Q9. 

Conclusions
 

Page 29 GAO-13-318 Offshore Tax Evasion

unreported offshore income. Through these programs, IRS has collected 

more than $5.5 billion to date, brought tens of thousands of taxpayers into 

compliance, and gained increased information on offshore 

noncompliance. It is unclear how many additional U.S. taxpayers have 

undeclared foreign accounts and how much unreported income is 

associated with those accounts. However, the number of quiet 

disclosures IRS was able to find (some by accident), the number of 

potential quiet disclosures we identified, and the sharp upswing in Form 

1040, Schedule B and FBAR filings all suggest that the amount of 

revenue to be collected from previously undisclosed offshore accounts 

could be significant.

We found two key issues that, if addressed, could make IRS’s offshore 

programs even more successful.

• IRS has not used program information to identify populations of 

taxpayers that would benefit from education and outreach regarding 

their offshore tax reporting obligations. Such information could 

promote voluntary compliance and reduce the need for enforcement 

actions. Additionally, IRS does not obtain information on how 

taxpayers learned about offshore programs. Without this information, 

IRS cannot fully evaluate its efforts to promote taxpayer participation 

in offshore programs.

• IRS may have missed taxpayers attempting to circumvent some of the 

taxes, interest, and penalties that would otherwise be owed in its 

offshore programs. Our methodology to identify potential quiet 

disclosures found many more potential disclosures than IRS detected. 

IRS may also have missed other attempts at circumvention by not 

researching the upward trends of taxpayers reporting offshore 

accounts for the first time. While there would be costs to such efforts, 

the amount already collected by the offshore programs suggests that 

considerable additional revenue gains might be possible. By 

identifying taxpayers attempting to circumvent some of the taxes, 

interest, and penalties that would otherwise be owed in its offshore 

programs, and taking appropriate action, IRS could potentially 

increase revenues, bolster the overall fairness of the program, and 

have a more informed basis for improving voluntary compliance.

We recommend that the Acting Commissioner of Internal Revenue take 

the following four actions: Recommendations for 

Executive Action
 

Page 30 GAO-13-318 Offshore Tax Evasion

• Use data gained from offshore programs to identify and educate 

populations of taxpayers that might not be aware of their tax 

obligations related to offshore income and FBAR filing requirements.

• Obtain information that can help IRS test offshore program promotion 

strategies and identify new ones by adding a question to current and 

future programs to determine how participants found out about the 

program.

• Explore options for employing a methodology for identifying and 

pursuing potential quiet disclosures to provide more assurance that 

actual quiet disclosures are not being missed and then implement the 

best option.

• Conduct an analysis designed to measure the extent that taxpayers 

are reporting existing foreign accounts on the Form 1040, Schedule B 

or on FBARs for the first time and circumventing some of the taxes, 

interest, and penalties that would otherwise be owed, and take 

appropriate action based on the analysis.

We provided a draft of this report to the Acting Commissioner of Internal 

Revenue for comment. In written comments, reproduced in appendix IX, 

IRS agreed with our four recommendations. IRS noted that it was pleased 

that we recognized the overall success of its offshore strategy and 

provided steps that they are taking to implement our recommendations 

and address any identified noncompliance, as warranted. IRS also 

provided technical comments on our draft report, which we incorporated, 

as appropriate. 

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to report to the Chairmen 

and Ranking Members of other Senate and House committees and 

subcommittees that have appropriation, authorization, and oversight 

responsibilities for IRS. We are also sending copies to the Acting 

Commissioner of Internal Revenue, the Secretary of the Treasury, the 

Chairman of the IRS Oversight Board, and the Deputy Director for 

Management of the Office of Management and Budget. In addition, the 

report will be available at no charge on the GAO website at 

http://www.gao.gov. 

Agency Comments

and Our Evaluation
 

Page 31 GAO-13-318 Offshore Tax Evasion

If you or your staffs have any questions about this report, please contact 

me at (202) 512-9110 or whitej@gao.gov. Contact points for our Offices 

of Congressional Relations and Public Affairs may be found on the last 

page of this report. GAO staff who made key contributions to this report 

are listed in appendix X.

James R. White

Director, Tax Issues

Strategic Issues
Appendix I: Objectives, Scope and 

Methodology

Page 32 GAO-13-318 Offshore Tax Evasion

The objectives of this report were to (1) describe the nature of the 

noncompliance of taxpayers participating in the 2009 Offshore Voluntary 

Disclosure Program (OVDP), (2) determine the extent to which Internal 

Revenue Service (IRS) used data from the 2009 OVDP in order to better 

prevent and detect future noncompliance, and (3) assess IRS’s efforts to 

identify taxpayers who may have attempted quiet disclosures or other 

ways of circumventing some of the taxes, interest, and penalties that 

would otherwise be owed in its offshore programs.

To describe the characteristics of taxpayers participating in the 2009 

OVDP, we relied on data for tax years 2003 through 2008 from four 

sources: (1) the Criminal Investigation Management Information System 

(CIMIS) managed by IRS’s Criminal Investigation (CI) division; (2) the 

Currency and Banking Retrieval System managed by the Treasury 

Department’s Financial Crimes Enforcement Network (FinCEN);1

Using these sources, we identified 19,337 participants in the 2009 

OVDP.

 (3) 

IRS’s Individual Master File and Business Master File; and (4) IRS’s 

Compliance Data Warehouse (CDW). We used data from four databases 

in CDW: Enforcement Revenue Information System, Individual Returns 

Transaction File, Audit Information Management System, Individual, and 

Business Returns Transaction File. To determine the reliability of IRS’s 

taxpayer data, we reviewed relevant documentation, conducted 

interviews with IRS officials knowledgeable of the data, and conducted 

electronic testing of the data to identify obvious errors or outliers. We 

determined that these data were sufficiently reliable for our purposes.

2

 

1

FBAR forms are processed by the IRS, but FBAR information is managed by Treasury’s 

FinCEN.

The 2009 OVDP population figure that we use in this report 

differs from the population number issued publicly by IRS. IRS’s publicly 

reported numbers are from CI, the IRS division that initially received and 

processed the 2009 OVDP applications, and is generally a count of 

applicants. Our figure is larger, primarily because it includes some 

spouses that were not captured on the CI list. For example, we counted 

two participants (versus instances where IRS may have only counted 

2

This population includes 200 participants with an Employer Identification Number (EIN), 

which IRS uses to identify businesses, instead of an Individual Tax Identification Number 

or Social Security Number. Since these business entities represented less than 1 percent 

of the total OVDP participants identified, our use of the term “OVDP participants” in this 

report generally refers to individual taxpayers participating in the program.

Appendix I: Objectives, Scope and 

Methodology 
Appendix I: Objectives, Scope and 

Methodology

Page 33 GAO-13-318 Offshore Tax Evasion

one) in situations where only one spouse applied to the 2009 OVDP 

through CI, but both were liable for the delinquent taxes, interest, and 

penalties because of their married filing jointly filing status. From the 

19,337 participants, we identified 10,439 closed examination cases as of 

November 29, 2012, which we use in this report for our analysis of 

penalties.

To obtain a better understanding of taxpayer noncompliance, we selected 

a random sample of 30 2009 OVDP case files for cases that were closed 

as of March 30, 2012, and that received a 2009 OVDP penalty of $1 

million or greater.3

We used a standard data collection instrument to review each case file to 

ensure we consistently captured information about the 2009 OVDP 

participants, their offshore accounts, and their penalties, interest, and 

additional taxes owed. To ensure reliability, two analysts separately 

conducted this analysis, and a third analyst compared and reconciled any 

inconsistencies regarding the categorizations of 2009 OVDP cases. The 

analysts then tallied the number of observations for each topic or 

category and all information was traced and verified. We then analyzed 

the results of this data collection effort to identify main themes and 

develop summary findings. We determined that these data were 

sufficiently reliable for our purposes. (See app. VII for a summary of our 

data collection instrument results.)

As part of the 2009 OVDP application, taxpayers were 

asked to explain their reasons for establishing offshore accounts, the 

source of funds, the ownership structure, and the history of accounts. 

Many taxpayers in our sample submitted an IRS optional letter containing 

this information with their application (referred to in this report as the 

“application letter.” See appendix III for sample application letters). Some

taxpayers were interviewed by IRS investigators, and some responded to 

IRS follow-up requests for additional information. Additionally, other case 

file documents that provided key information were: (1) IRS Form 906, 

Closing Agreement On Final Determination Covering Specific Matters; (2) 

IRS Form 4549-A, Income Tax Discrepancy Adjustments; (3) OVDP 

Penalty Computation Workpaper; and (4) form TD F 90-22.1, Report of 

Foreign Bank and Financial Accounts (FBAR).

 

3

We focused on cases with an OVDP penalty of $1 million or greater because these “large 

penalty” cases accounted for about half of the total OVDP penalty dollars assessed. At the 

time we selected our sample of 30 cases in April 2012, we had identified a total population 

of 378 “large penalty” cases that were closed as of March 30, 2012. 
Appendix I: Objectives, Scope and 

Methodology

Page 34 GAO-13-318 Offshore Tax Evasion

To determine the extent to which IRS used data from the 2009 OVDP in 

order to better prevent and detect future noncompliance, we also 

interviewed IRS officials from the office of the Offshore Compliance 

Initiative to determine what data they collected from the 2009 OVDP effort 

and how, if at all, IRS used that data to create taxpayer profile data to 

identify additional offshore noncompliance and inform future offshore 

programs. In addition, we reviewed changes that IRS made to the 2011 

and 2012 offshore programs.

To assess IRS’s efforts to identify taxpayers who may have attempted 

quiet disclosures, we used the same datasets that we used to identify the 

2009 OVDP population, as described above, plus FBAR data from 

FinCEN. To determine the reliability of FinCEN’s FBAR data, we reviewed 

relevant documentation, conducted interviews with FinCEN officials 

knowledgeable of the data, and conducted electronic testing of the data to 

identify errors or outliers. We determined that these data were sufficiently 

reliable for our purposes. To identify potential quiet disclosures we 

conducted a three-step analysis. First, we used IRS tax return data to 

identify taxpayers who filed late or amended returns for the applicable 

2009 OVDP period.4

 

4

This included individuals or businesses who filed one or more amended or late returns for 

any of the six tax years included in the 2009 OVDP (tax year 2003 through tax year 2008), 

and whose amended or late returns were posted in IRS’s Individual Master File or 

Business Master File systems in calendar years 2009 and 2010. Taxpayers could apply to 

the 2009 OVDP program from March 23 through October 15, 2009, but they could still file 

amended returns after this period. We discussed our intended use of this data along with 

our methodology with IRS officials. They agreed with our use of the data and our 

methodology.

We then used FBAR data to identify taxpayers who 

filed late or amended FBARs during the same time period to create a 

combined list of taxpayers. Finally, we removed from this combined list 

any taxpayers that we had previously identified as 2009 OVDP 

participants. The remaining taxpayers constitute our population of 

taxpayers who potentially “quietly disclosed” offshore accounts. From this 

population, we used data from amended tax returns to identify whether 

the amended returns had positive adjustments to income, and whether 

taxpayers filed amended returns for multiple years. We confirmed this 

methodology with IRS officials. The results of our analyses are shown in 

appendix VIII. To assess other ways taxpayers might be circumventing 

some of the taxes, interest, and penalties that would be otherwise owed, 

we analyzed filing trends in FBAR data from FinCEN and in Schedule B, 

Interest and Ordinary Dividends, of IRS Form 1040, U.S. Individual 
Appendix I: Objectives, Scope and 

Methodology

Page 35 GAO-13-318 Offshore Tax Evasion

Income Tax Return, from IRS’s Statistics of Income Division (SOI). To 

assess the reliability of the SOI data that we analyzed, we reviewed 

agency documentation and interviewed officials familiar with the data. We 

determined that these data were sufficiently reliable for our purposes.
Appendix II: Events that Influenced 

Participation in IRS’s Offshore Programs

Page 36 GAO-13-318 Offshore Tax Evasion

IRS’s first offshore program started in 2003 as part of an ongoing, 

multipronged effort to counter offshore tax evasion. Related to the 2003 

program was the Offshore Credit Card Program, which stemmed from a 

series of John Doe summonses issued to a variety of financial and 

commercial businesses to obtain information on U.S. persons who held 

credit, debit, or other payment cards issued by offshore banks. IRS used 

records from the summonses to trace the identities of taxpayers whose 

use of these payment cards may have been related to hiding taxable 

income; this drew many other taxpayers to the offshore program.1

IRS’s three subsequent offshore voluntary disclosure programs ran more 

frequently, starting in 2009. The 2009 Offshore Voluntary Disclosure 

Program (OVDP) coincided with events that helped attract a very large 

number of taxpayers to the program. On February 18, 2009, UBS AG, a 

global financial services firm headquartered in Switzerland, entered into a 

deferred prosecution agreement confirming the account of a 

whistleblower and acknowledging that its employees participated in a 

scheme to actively assist and facilitate U.S. taxpayers’ concealment of 

taxable income.

 (See 

figure 5 for a timeline of key events.)

2

 

1

We testified on IRS’s 2003 offshore voluntary compliance program in 2009. See GAO, 

Tax Compliance: Offshore Financial Activity Creates Enforcement Issues for IRS,

As part of the deferred prosecution agreement, UBS 

agreed to turn over identities and account information on a limited number 

of clients. Later that month, the Department of Justice (DOJ) petitioned 

the U.S. District Court in Miami for an order enforcing a John Doe 

summons, seeking turnover of information on approximately 52,000 

undisclosed accounts. By August 2009, IRS and DOJ announced they 

had reached a settlement agreement with Switzerland. The agreement 

required Swiss authorities to give IRS the names of approximately 4,450 

U.S. clients with accounts at UBS, pursuant to a request under the USASwitzerland income tax treaty. All parties agreed to keep confidential the 

GAO-09-478T (Washington, D.C.: Mar. 17, 2009). 

2

The Internal Revenue Code provides whistleblowers with a significant financial incentive 

to report noncompliance. It provides for awards up to 30 percent of the collected proceeds 

that arise from the whistleblower’s information. 26 U.S.C. § 7623. A whistleblower is 

someone who reports information on potential tax problems, such as fraud, to the IRS.

Although not publicly confirmed by IRS, attorneys for the UBS whistleblower reported that 

he was awarded $104 million. For additional information on tax whistleblowers, see GAO, 

Tax Whistleblowers: Incomplete Data Hinders IRS’s Ability to Manage Claim Processing 

Time and Enhance External Communication, GAO-11-683 (Washington, D.C.: Aug. 10, 

2011).

Appendix II: Events that Influenced 

Participation in IRS’s Offshore Programs
Appendix II: Events that Influenced 

Participation in IRS’s Offshore Programs

Page 37 GAO-13-318 Offshore Tax Evasion

specific criteria by which the 4,450 accounts would be selected until after 

the 2009 OVDP deadline passed. This created uncertainty among UBS 

account holders as to whether their names were on the list to be 

disclosed. IRS gave taxpayers until October 15, 2009, to enter the 

program. IRS publicity about the program, and correspondence sent by 

UBS to all U.S. account holders, emphasized the several criminal and 

civil penalties applicable to taxpayers who did not make voluntary 

disclosures before Switzerland turned over the account data.

The 2011 and 2012 programs had a similar draw for taxpayers. During 

the 2011 program, IRS and DOJ were building cases against tax evasion 

involving foreign banks in several countries, including Switzerland, 

Liechtenstein, Israel, and India. Many 2011 program participants came 

forward as a result of criminal enforcement activity and a John Doe 

summons issued to HSBC, a global banking and financial services firm 

headquartered in the United Kingdom, with significant business 

operations in Hong Kong and Asia. The 2012 program, which is still open 

and as of March 2013 does not have an end date, is expected to draw 

participants based on further criminal enforcement activity against foreign 

banks and opportunities for additional John Doe summonses that are 

being built by IRS and DOJ with information from past offshore programs. 

Also during this time, as the Foreign Account Tax Compliance Act 

(FATCA) becomes fully implemented, IRS expects to have increased 

information reporting from certain taxpayers and from foreign financial 

institutions on offshore accounts.
Appendix II: Events that Influenced 

Participation in IRS’s Offshore Programs

Page 38 GAO-13-318 Offshore Tax Evasion

Figure 5: Events That Influenced Participation in IRS’s Offshore Programs

Note: OVDP refers to Offshore Voluntary Disclosure Program and FATCA refers to Foreign Account 

Tax Compliance Act. 
Appendix III: Sample 2009 and 2012 Offshore 

Program Application Letters

Page 39 GAO-13-318 Offshore Tax Evasion

Appendix III: Sample 2009 and 2012 Offshore 

Program Application Letters

2009 Application Letter

The 2009 application 

letter was optional for 

participants in the 2009 

Offshore Voluntary 

Disclosure Program 

(OVDP).
Appendix III: Sample 2009 and 2012 Offshore 

Program Application Letters

Page 40 GAO-13-318 Offshore Tax Evasion
Appendix III: Sample 2009 and 2012 Offshore 

Program Application Letters

Page 41 GAO-13-318 Offshore Tax Evasion
Appendix III: Sample 2009 and 2012 Offshore 

Program Application Letters

Page 42 GAO-13-318 Offshore Tax Evasion

2012 Application Letter 

and New Required 

Attachment

IRS revised the 2009 

application letter for 

subsequent programs, 

and included an 

attachment that required 

a more detailed reporting 

from taxpayers on their 

previously unreported 

offshore accounts. The 

2012 application letter 

was required for all 

participants in the 2012 

offshore program.
Appendix III: Sample 2009 and 2012 Offshore 

Program Application Letters

Page 43 GAO-13-318 Offshore Tax Evasion
Appendix III: Sample 2009 and 2012 Offshore 

Program Application Letters

Page 44 GAO-13-318 Offshore Tax Evasion
Appendix III: Sample 2009 and 2012 Offshore 

Program Application Letters

Page 45 GAO-13-318 Offshore Tax Evasion
Appendix III: Sample 2009 and 2012 Offshore 

Program Application Letters

Page 46 GAO-13-318 Offshore Tax Evasion
Appendix III: Sample 2009 and 2012 Offshore 

Program Application Letters

Page 47 GAO-13-318 Offshore Tax Evasion
Appendix III: Sample 2009 and 2012 Offshore 

Program Application Letters

Page 48 GAO-13-318 Offshore Tax Evasion
Appendix III: Sample 2009 and 2012 Offshore 

Program Application Letters

Page 49 GAO-13-318 Offshore Tax Evasion
Appendix IV: Hypothetical Examples 

Comparing Account Balances, Length of 

Account Ownership, and Penalties

Page 50 GAO-13-318 Offshore Tax Evasion

The 2009 Offshore Voluntary Disclosure Program (OVDP) penalties 

follow what some tax practitioners have called “rough justice” because of 

the relationship between the offshore penalties and the original taxes 

evaded. Figure 6 illustrates how two hypothetical offshore accounts 

bearing 5 percent interest might grow over time. One account is owned by 

a compliant taxpayer who reports the interest income and pays U.S. taxes 

at a 35 percent rate with earnings from the account. The other account is 

owned by a noncompliant taxpayer who does not report the interest 

income. Assuming both taxpayers deposited $1 million in 1986, the 

compliant taxpayer would accumulate a balance of approximately $2.1 

million by 2009 and the noncompliant taxpayer would accumulate $3.1 

million. The compliant taxpayer would have paid tax in each year the 

account was open, totaling about $585,000 in cumulative taxes on the 

reported account’s interest over 23 years. A noncompliant taxpayer who 

participated in the 2009 OVDP would, after disclosing the account, make 

a one-time payment in 2009 of about $993,000 in taxes, interest, and 

penalties. Although the 2009 OVDP participant would pay more in total 

taxes and penalties, the final account balances for both taxpayers would 

be roughly the same.

Appendix IV: Hypothetical Examples 

Comparing Account Balances, Length of 

Account Ownership, and Penalties
Appendix IV: Hypothetical Examples 

Comparing Account Balances, Length of 

Account Ownership, and Penalties

Page 51 GAO-13-318 Offshore Tax Evasion

Figure 6: Hypothetical Comparison of Offshore Account Growth for Compliant

(Reported and Taxed) and Noncompliant (Unreported and Untaxed) Taxpayers, and 

Changes in Account Balances by Participating in the 2009 OVDP

Note: The following assumptions were used to construct the figure: (1) a $1 million opening account 

balance; (2) 5 percent annual rate of return on the offshore account; (3) 35 percent U.S. income tax 

rate and zero offshore tax rate; (4) 20 percent 2009 OVDP offshore penalty applied to the account 

balance; (5) 20 percent accuracy-related penalty on the taxes owed for tax year 2003 through tax 

year 2008; and (6) IRS interest of 5 percent on taxes owed for tax year 2003 through tax year 2008. 

The point at which the compliant taxpayer’s account balance (solid black line) equals the 2009 OVDP 

participant’s post-penalty balance (dashed grey line) is affected by changes in the assumptions. For 

example, a higher rate of return on the offshore account shortens this “rough justice” point, whereas a 

higher 2009 OVDP offshore penalty rate (greater than 20 percent) lengthens it. 

Using the same hypothetical model from figure 6 can help illustrate how 

taxpayers with newer offshore accounts that have not accumulated 

decades of untaxed interest income are treated. Assuming the 

hypothetical accounts in figure 6 were opened in 2004 (instead of 1986), 

the compliant taxpayer would have paid about $93,000 in taxes on the 

interest income and accumulated a balance of about $1.2 million by 2009, 

and the noncompliant taxpayer paying no taxes would have accumulated 

about $1.3 million. If the noncompliant taxpayer came forward through the 

2009 OVDP, the penalties, interest, and delinquent taxes would have 

totaled about $387,000. The 2009 OVDP participant’s ending account 
Appendix IV: Hypothetical Examples 

Comparing Account Balances, Length of 

Account Ownership, and Penalties

Page 52 GAO-13-318 Offshore Tax Evasion

balance would be about $890,000, which is less than the original opening 

deposit amount.
Appendix V: 2009 Offshore Voluntary 

Disclosure Program Participants with 

Employer Identification Numbers

Page 53 GAO-13-318 Offshore Tax Evasion

We identified 200 2009 OVDP participants with an Employer Identification 

Number (EIN), which is used by IRS to identify a business entity. We did 

not have complete information on all of the businesses in our sample. In 

addition, not all of the businesses had filing requirements in every year 

covered by the 2009 OVDP. Table 4 shows the tax forms filed by some of 

the businesses in tax year 2008, and table 5 shows the self-reported 

North American Industry Classification System (NAICS) code.

Table 4: 2008 Business Filing Requirements for 2009 OVDP Business Participants

Filing requirement Count of EINsa

Form 1041 and 1041A (estates and trusts) 27

Form 1065 (partnership income) 9 

Form 1120 (U.S. corporation) 66

Source: GAO analysis of IRS’s Compliance Data Warehouse and Business Returns Transactions File.

a

Some 2009 OVDP businesses may not have a filing requirement or may not have filed during tax 

year 2008

Table 5: Self-Reported Industry Code on 2008 Tax Return for 2009 OVDP 

Businesses

NAICS category/CIMIS description

Count of 

EINsa Percent of 

EINs

Agriculture, forestry, fishing and hunting 2 1.1

Mining, quarrying, and oil and gas extraction 2 1.1

Construction 6 3.3

Manufacturing 4 2.2

Wholesale trade 14 7.6

Retail trade 8 4.4

Transportation and warehousing 2 1.1

Information (publishing, newspaper, etc.) 3 1.6

Finance and insurance 12 6.5

Real estate and rental and leasing 9 4.9

Professional, scientific, and technical services 16 8.7

Management of companies and enterprises 4 2.2

Administrative and support and waste management and 

remediation services

2 1.1

Educational services 2 1.1

Health care and social assistance 5 2.7

Arts, entertainment, and recreation 6 3.3

Accommodation and food services 4 2.2

Appendix V: 2009 Offshore Voluntary 

Disclosure Program Participants with 

Employer Identification Numbers
Appendix V: 2009 Offshore Voluntary 

Disclosure Program Participants with 

Employer Identification Numbers

Page 54 GAO-13-318 Offshore Tax Evasion

NAICS category/CIMIS description

Count of 

EINsa Percent of 

EINs

Other services (except public administration) 4 2.2

Estate or trust based on CIMIS name description 66 35.9

NAICS unknown, not estate or trust 13 7.1

Source: GAO analysis of IRS’s Compliance Data Warehouse and Business Returns Transactions File.

a

Some 2009 OVDP businesses may not have a filing requirement or may not have filed during tax 

year 2008
Appendix VI: Additional 2009 Offshore 

Voluntary Disclosure Program Participant 

Characteristics 

Page 55 GAO-13-318 Offshore Tax Evasion

Taxpayers participating in the 2009 OVDP most often used the married 

filing jointly filing status, were most often age 55 and over, and had an 

average adjusted gross income of about $528,000, as show in table 6.

Table 6: Taxpayer and 2009 OVDP Participant Income and Demographics for Tax Year 2008 

Returns filed for tax year 2008

All tax returns 2009 OVDP returns

Filing status 

Number 

of returns

Percent of 

all returns

Number 

of returns

Percent of 

all returns

Single 64,896,521 46 2,890 27

Married filing jointly 53,655,844 38 6,708 64

Married filing separately 2,717,037 2 608 6 

Head of household 21,098,890 15 332 3 

Surviving spouse 82,276 <1 5 <1

Age

65 and over 19,963,516 14 3,864 37

55 under 65 19,662,988 14 2,584 25

45 under 55 26,091,781 18 2,191 21

35 under 45 25,515,310 18 1,304 12

26 under 35 23,923,140 17 451 4 

under 26 25,623,607 18 121 1 

unknown 1,670,226 1 28 <1

Adjusted gross income (AGI)

Mean AGI $58,005 $527,610

Median AGI $32,261 $136,878

Source: GAO analysis of IRS’s Individual Returns Transaction File and Statement of Income databases.

Appendix VI: Additional 2009 Offshore 

Voluntary Disclosure Program Participant 

Characteristics 
Appendix VII: Data Collected from a Sample of 

30 2009 Offshore Voluntary Disclosure 

Program Case Files with Large Penalties

Page 56 GAO-13-318 Offshore Tax Evasion

As noted in appendix I, we used a standard data collection instrument to 

capture information from a sample of 30 2009 OVDP cases in which 

taxpayers received offshore penalties of $1 million or greater. We then 

analyzed the results to identify main themes, and develop the summary 

findings presented in this report. The information in this appendix contains 

information from our case file reviews.

We calculated offshore account balances based on penalty information.

For our sample of 30 cases, the average account balance was almost 

$15 million, as shown in table 7 with other key information.

Table 7: Selected Offshore Account Balances, Taxes, and Penalties from a Case 

Study of 30 2009 OVDP Cases with Penalties of $1 Million or Greater 

 Mean Median

Adjusted gross income, tax year 2008a $2,550,043 $359,333

Offshore account(s) balanceb 14,674,778 7,898,603

OVDP penalty assessed 2,934,956 1,579,721

Additional tax, tax years 2003-2008c 851,745 480,318

Interest, tax years 2003-2008 264,686 146,856

Other penaltiesd 196,754 102,877

Total penalties, taxes, and interest 4,218,937 2,420,399

Source: GAO analysis of IRS’s Enforcement Revenue Information System, and Individual Returns Transaction File.

Note: The cases were randomly selected to the population with penalties of $1 million or greater, but 

due to the small number of cases, we do not recommend generalizing the mean and median to the 

population. The sum of components may not add to the total. 

a

Adjusted gross income is from original, not amended, returns. 

b

OVDP offshore account balance is an estimated number based on penalty amounts. It represents 

the highest aggregate balance of all offshore accounts between 2003 and 2008. 

c

For a few cases in our sample, no additional tax or interest was assessed. 

d

Other penalties include delinquency penalties and accuracy-related penalties, which most taxpayers 

in our sample received. 

Most of the 30 cases we reviewed contained some information about the 

bank names and country locations of the offshore accounts. In some 

cases, 2009 OVDP participants disclosed dozens of offshore accounts 

with multiple banks and in multiple countries; in other cases, participants 

reported only one account. Only those offshore accounts that were open 

in tax year 2003 through tax year 2008 were included in the calculation of 

the 20 percent 2009 OVDP penalty. In compiling our profile, we only 

Appendix VII: Data Collected from a Sample 

of 30 2009 Offshore Voluntary Disclosure 

Program Case Files with Large Penalties

Account Balances and 

Total Penalties, Taxes, and 

Interest

Bank Locations and Names
Appendix VII: Data Collected from a Sample of 

30 2009 Offshore Voluntary Disclosure 

Program Case Files with Large Penalties

Page 57 GAO-13-318 Offshore Tax Evasion

included information on accounts that were open during the 2009 OVDP 

applicable period and included in the penalty calculation. (Some 

participants disclosed additional offshore accounts that were closed prior 

to 2003 and not part of the 2009 OVDP penalty calculation.) Figure 7 

illustrates the most commonly disclosed country locations. A total of 17 

different locations were noted in the 28 cases that disclosed locations, 

with Switzerland being the most commonly reported location.

Figure 7: Locations of Offshore Accounts as Disclosed in a Sample of 30 2009 

OVDP Cases with Penalties of $1 Million or Greater

Note: The total number of countries exceeds the total number of case files we reviewed (30) because 

some taxpayers had accounts in multiple locations. 

a

Caribbean region could include Bermuda, British Virgin Islands, and Cayman Islands. 

b

Six cases disclosed offshore accounts in a total of nine other countries, and each country appeared 

once in our sample. 

Figure 8 illustrates the most commonly disclosed bank names. A total of 

42 different banks were reported in the 29 cases that contained bank 

name information, with UBS by far the most commonly disclosed bank 

name, followed by Swiss banks Julius Baer, and Credit Suisse.
Appendix VII: Data Collected from a Sample of 

30 2009 Offshore Voluntary Disclosure 

Program Case Files with Large Penalties 

Page 58 GAO-13-318 Offshore Tax Evasion

Figure 8: Bank Names of Offshore Accounts as Reported in a Sample of 30 2009 

OVDP Cases with Penalties of $1 Million or Greater

Note: The total number of bank names exceeds the total number of case files we reviewed (30) 

because some taxpayers had accounts in multiple banks. 

a

17 cases disclosed other bank names that appeared less frequently (only once) in our sample. In 9 

of these cases, one or more accounts were with other Swiss banks not named above. 

Twenty-two of the case files we reviewed contained information about the 

history of the accounts and the nature of the taxpayer’s noncompliance. 

Many of the accounts had been opened decades ago. The median period 

of time that participants had owned but not reported income from these 

accounts, was 18 years, and the average period was 25 years. In four 

cases, the participants had owned offshore accounts for 50 years or 

longer.

Table 8 summarizes key information from the data collection instrument 

we used to collect information on the 30 offshore case files we reviewed. 

Age of Accounts

Summary of Data 

Collection Instrument 

Results
Appendix VII: Data Collected from a Sample of 

30 2009 Offshore Voluntary Disclosure 

Program Case Files with Large Penalties 

Page 59 GAO-13-318 Offshore Tax Evasion

Table 8: Selected Data Collection Instrument Questions and Response Counts from 

Sample of 30 2009 OVDP Case Files with Penalties of $1 Million or Greater

Frequency

Yes No

Not in 

filea

Citizenship, and residency

Is the taxpayer (or spouse) a U.S. citizen? 23 1 6 

If yes, is the taxpayer (or spouse) a naturalized citizen? 7 13 3 

If yes, is the taxpayer (or spouse) a dual citizen? 3 20 0 

Do the taxpayer(s) reside outside the U.S.? 3 26 1 

Account(s) histories

Were any of the offshore accounts with UBS? 21 8 1 

Did the taxpayer (or spouse) open the offshore account(s) while a 

non-U.S. resident? 

10 12 8 

Did the taxpayer (or spouse) inherit the offshore account(s) from a 

spouse, parent, or other relative?

14 9 7 

If inherited, did the prior owner open the account(s) while a 

non-U.S. resident?

11 0 3 

If inherited, was the prior owner not a U.S. citizen? 6 7 1 

If inherited, was the prior owner a Holocaust survivor? 5 5 4 

Ownership types

Did the taxpayer(s) jointly own or manage the account(s) with 

other family or relatives (other than spouses)?

7 16 7 

Did other family or relatives also disclose offshore accounts? 10 0 20

Did the taxpayer(s) own or manage the account(s) through foreign 

corporations, trusts, foundations or other offshore entities?

12 0 18

Taxes paid

Did the taxpayer(s) pay U.S. taxes on any of the funds originally 

deposited into the account(s)? 

7 10 13

Did the case file indicate that the taxpayer paid foreign income 

taxes?

16 12 2 

Source of funds

Was the original source of funds deposited into the accounts:b 

an inheritance? 14 10 6 

non-U.S. source income? 11 13 6 

U.S. source income? 5 19 6 

Source: GAO analysis of 30 2009 OVDP case files with penalties of $1 million or greater.

a

In some cases, there was insufficient information in the case file to answer these questions. 

b

In some cases, taxpayers disclosed that funds in their offshore accounts came from a combination of 

sources including U.S. and non-U.S. sources. 
Appendix VIII: Quiet Disclosure Analysis 

Results 

Page 60 GAO-13-318 Offshore Tax Evasion

Using a methodology that we designed to detect potential quiet 

disclosures, as described in appendix I, we identified the following.

Potential Quiet Disclosures Individuals

• 9,884 Taxpayers Identification Numbers (TIN) = Filed amended 

returns or late returns and FBARs in calendar year 2009 and calendar 

year 2010

• 7,440 of the 9,884 TINs = Had non-zero change in tax liability, of 

which 6,668 TINs had a positive change (i.e., owed taxes based 

on the amended return), in at least one tax year between tax year 

2003 and tax year 2008.

• 3,240 of the 9,884 TINs = In calendar year 2009 and calendar 

year 2010, filed late or amended returns with FBARs for more 

than one tax year between tax year 2003 and tax year 2008

Potential Quiet Disclosures Businesses

• 711 Employee Identification Numbers (EIN) = Filed amended returns 

or late filed returns and FBARs in calendar year 2009 and calendar 

year 2010

• 710 of the 711 EINs = Had non-zero change in tax liability, of 

which 427 had a positive change in tax liability (i.e., owed taxes 

based on the amended return) in at least one tax year between 

tax year 2003 and tax year 2008

• 146 of the 711 EINs = In calendar year 2009 and calendar year 

2010, filed late or amended returns with FBARs for more than one 

tax year between tax year 2003 and tax year 2008

Potential Quiet Disclosures Individuals and Businesses, Combined Totals

• 10,595 TINs and EINs = Filed amended returns or late returns and 

FBARs in calendar year 2009 and calendar year 2010.

• 8,150 of the 10,595 TINs and EINs = Had non-zero change in tax 

liability, of which 7,095 had a positive change in tax liability (i.e., 

owed taxes based on the amended return) in at least one tax year 

between tax year 2003 and tax year 2008

• 3,386 of the 10,595 TINs and EINs = In calendar year 2009 and 

calendar year 2010, filed late or amended returns with FBARs for 

more than one tax year between tax year 2003 and tax year 2008

• Of the 3,386 TINs and EINs, 94 filed late or amended returns with 

FBARs for all tax years between tax year 2003 and tax year 2008

Appendix VIII: Quiet Disclosure Analysis 

Results 
Appendix IX: Comments from the Internal 

Revenue Service 

Page 61 GAO-13-318 Offshore Tax Evasion

Appendix IX: Comments from the Internal 

Revenue Service
Appendix IX: Comments from the Internal 

Revenue Service 

Page 62 GAO-13-318 Offshore Tax Evasion
Appendix IX: Comments from the Internal 

Revenue Service 

Page 63 GAO-13-318 Offshore Tax Evasion
Appendix IX: Comments from the Internal 

Revenue Service 

Page 64 GAO-13-318 Offshore Tax Evasion
Appendix X: GAO Contact and Staff 

Acknowledgments

Page 65 GAO-13-318 Offshore Tax Evasion

James R. White, (202) 512-9110 or whitej@gao.gov. 

In addition to the contact named above, Mark Abraham, Tara Carter

(Analyst-In-Charge), Andrew Ching, Leon Green, Mark Kehoe, and Libby 

Mixon (Assistant Director) made contributions to the report. Jeff Arkin, 

Chuck Fox, Robert Gebhart, George Guttman, Brian James, Sarah 

McGrath, Donna Miller, John Mingus, Ed Nannenhorn, Karen O’Conor, 

Robert Robinson, Cynthia Saunders, Andrew Stephens, Wayne Turowski, 

Jim Ungvarsky, and John Zombro provide key assistance. 

Appendix X: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments

(450914)
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