Sir, - We refer to your coverage (Business, August 14th) of the Institute of Taxation in Ireland's position on the issue of bogus non-resident accounts.
The report referred to the Revenue's Statement of Practice (SOP) on "Underlying Tax on Funds Deposited in Bogus Non-Resident Accounts", issued on May 2nd last.
We are somewhat surprised and disappointed that a statement issued by a firm of financial and business consultants has suggested that bogus non-resident account holders might be lulled into a false sense of security, and might not comply with the scheme, as a result of our advice to members.
In fact, our advice to members did not suggest that taxpayers should not take the opportunity to make full and complete declarations to the Revenue. The institute has not discouraged taxpayers from availing themselves of this opportunity to voluntarily disclose historic tax liabilities by November 15th. On the contrary, it has informed its members (i.e. tax practitioners) that they must cease to act on behalf of any relevant client who decides not to avail of the SOP where the member has knowledge of this fact.
There are clear benefits to taxpayers who are entitled to avail of the SOP where they make full and complete declarations, and payment of tax and relevant penalties, by November 15th.
Following careful consideration of the content of the SOP, the institute had a number of concerns about its practical application, and how this would affect its members in their dealings with taxpayers seeking advice on the SOP. The institute received clarification from the Revenue on a number of these issues.
To ensure its members were fully informed, the institute also sought legal advice from a leading senior counsel. All this information was circulated to members so that they could properly advise any clients wishing to avail themselves of the SOP.
The Institute of Taxation represents the professional interests of its 2,500 members and provides a range of services for them on a wide variety of tax-related issues. One of the services provided is the analysis of statements of practice issued by the Revenue Commissioners. - Yours, etc.,
John Bradley, President, Institute of Taxation in Ireland, Sandymount Avenue, Dublin 4.