The DOJ is given the green light to proceed with John Doe Summonses
The U.S. Department of Justice announced on January 30, 2025, that federal courts have authorized the DOJ to issue John Doe summonses to Trident Trust entities, seeking records on U.S. taxpayers who may have used offshore accounts to evade reporting obligations. This aggressive enforcement action underscores the IRS’ ongoing commitment to identifying and penalizing unreported foreign assets.
The US requires disclosure of certain offshore assets and activities, including foreign bank accounts. U.S. persons with foreign financial accounts exceeding $10,000 at any time during the year must file a Report of Foreign Bank and Financial Accounts (FBAR)—or risk severe civil and criminal penalties. Willful failure to file an FBAR can result in penalties up to the greater of $100,000 or 50% of the account balance per violation, with potential criminal exposure. Even non-willful violations can trigger penalties of $10,000 per year.
The Trident Trust summonses serve as a stark reminder: offshore secrecy is no longer a viable strategy. The IRS’ global reach, coupled with international information-sharing agreements, makes noncompliance riskier than ever. If you have undisclosed foreign accounts, now is the time to act. Voluntary disclosure options remain available, but once the IRS has you in its sights, your options become limited.
Don’t wait for the IRS to find you—proactively addressing offshore compliance issues is always the best strategy. If you need guidance on offshore reporting obligations or potential exposure, consult an experienced international tax attorney immediately. If you are facing international tax issues, the tax lawyers at Wiggam Law have the knowledge and experience to guide you through your unique situation. Call (404) 233-9800 or use our contact form to request a consultation.