Josh O. Ungerman was quoted in the BNA Daily Tax Report in the article, "Taxpayers Fear Disclosing Offshore Assets As Deadline Approaches, Practitioners Say."

Josh O. Ungerman was quoted in the BNA Daily Tax Report on August 15, 2011 in the article, "Taxpayers Fear Disclosing Offshore Assets As Deadline Approaches, Practitioners Say."  Article Quotes:

'Ungerman Says IRS 'Missing the Boat.  Pursuing these taxpayers may not reap great monetary returns for the U.S. government, said Josh O. Ungerman of Meadows, Collier, Reed, Cousins, Crouch & Ungerman LLP to BNA on Aug. 3.  IRS is "missing the boat" in imposing a 25 percent penalty in these cases, Ungerman said. The reality for those people is that it would be nice to have them in compliance in their country of residence.  Most practitioners who do a lot of this type of work have clients who are saying they're just not going to participate."

"The IRS has moved beyond Europe into the Far East and south of the United States as well," Ungerman said, noting that banking giant HSBC as well as Credit Suisse are now cooperating with U.S. tax authorities.  Yet, he said, many U.S. taxpayers with undisclosed offshore accounts at banks with branches in the United States still refuse to consider the IRS's voluntary disclosure program.  Those taxpayers, he said, face "almost certain disclosure to the IRS." Failure to come forward is 'the ultimate in ostrich behavior," he said.  Ungerman noted that taxpayers who banked at HSBC and other banks that have been "breached," such as UBS and Credit Suisse, are signing up for the OVDI. However, he said, "Many taxpayers with so much at risk, in countries with financial institutions that have not been publicly identified, are staying on the sidelines."  Ungerman said that willfully noncompliant taxpayers should come forward as soon as possible."