Brager Tax Law Group Obtains Over 6,500 Pages in Freedom of Information Act Request for Offshore Voluntary Disclosure Program Do

Dennis Brager, founder of the Brager Tax Law Group, received 6,500 document pages from the Internal Revenue Service as a result of the Freedom of Information Act (FOIA) Request he filed on behalf of the TaxProblemAttorney which is published by the Brager Tax Law Group. The information requested included material used in training IRS personnel in the Offshore Voluntary Disclosure Program (OVDP), determining Program penalties and instructing IRS employees on the Program. The OVDP is for those individuals who have failed to file an FBAR (Foreign Bank and Financial Accounts Report) form with the IRS, or failed to report income from offshore activities. The OVDP provides for a 27.5 percent penalty, but there are other options applicable to certain taxpayers which may provide additional relief.

"The OVDP is a complicated program with myriad, and sometimes conflicting, rules," Brager points out. "The interpretation of those rules is left in the hands of individual revenue agents whose decisions are reviewed not by the courts, but mysterious 'technical advisors' whose identities the IRS keeps secret, and with whom tax attorneys and their clients are not permitted to communicate directly." Brager continues, "We are hoping that these materials will help shed some light on how decisions are being made."

Brager initiated the FOIA request in April and received the files six months later. They arrived on a password protected CD with no particular organizational structure. The entire trove of thousands of pages is posted on the Brager website at Continue>>>