Swiss Bank Account Amnesty – Board-Certified Tax Law Specialist Attorney
In early 2018, the IRS supplemented its IRS Enforcement Priority list, to include multiple new “Enforcement Groups” of which the Internal Revenue Service will allocate significant resources.
Not surprisingly, one of the key priorities of which the IRS will be pursuing (aka issuing fines, penalties, and Audit/Examination Notices) is against individuals with unreported Swiss Bank Accounts.
Swiss Bank Program Campaign
The Swiss Bank Program Campaign was one of the first in a long list of settlement agreements the IRS entered into with several offshore financial institutions in order to reduce offshore evasion.
Essentially, under the terms of the program, Foreign Financial Institutions (FFIs) entered into settlement agreements to avoid U.S. prosecution.
In exchange for a waiver of prosecution, the Swiss Banks provided information regarding US account holders who have been secretly hiding accounts in the Swiss bank institutions to the IRS (so much for the financial confidentiality the Banks sold U.S. customers on back in the 70s, 80s, and 90s).
The IRS Catches Up
Many of these accounts were ‘number accounts,’ or accounts held by shadow companies or nominees.
Thus, by 2018, the IRS has amassed significant amounts of information. This is coupled by the fact that more than 110 foreign countries, and more than 300,000 Foreign Financial Institutions are voluntarily complying with FATCA Reporting. Therefore, with the wealth of information the IRS has at its disposal, along with the IRS’s ability to cross-reference this information in accordance with individual reporting requirements with Form 8938 and the FBAR (amongst others) the IRS has all the tools necessary to vet out who is properly complying international tax law and offshore reporting… and who isn’t.
**If you are one of the individuals who had accounts at one of these financial institutions you may consider immediately entering into one of the approved IRS offshore disclosure programs before it is too late.
Get Into IRS Offshore Compliance with Voluntary Disclosure
Offshore Voluntary Disclosure Tax law is very complex. There are many aspects that go into any particular tax calculation, including the legal status, marital status, business status and residence status of the taxpayer.
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