Swiss Government and US Government Announce New Program for Cooperation and Disclosure by Swiss Banks

- By : Parag Patel

In August 2013, the Swiss Federal Government and the DOJ announced a first of its kind program (the New Program) that will enable eligible Swiss banks to address and resolve…

IRS posts its “wins” involving offshore accounts

- By : Parag Patel

Swiss financial advisor, was indicted for conspiring with U.S. taxpayers and others to hide more than $184 million in offshore Swiss bank accounts. Aug. 21, 2009 — Former UBS banker…

ABA COMMENTS ON THE 2014 OFFSHORE VOLUNTARY DISCLOSURE PROGRAM AND THE STREAMLINED PROGRAMS

- By : Parag Patel

…Offshore Voluntary Disclosure Program (“OVDP”), the Streamlined Domestic Offshore Program (“SDOP”), and the Streamlined Foreign Offshore Program (“SFOP”).   The IRS voluntary disclosure programs have been remarkably successful with more…

US DOJ Tax Asst Attorney General Keneally Reports that One third of Swiss Banks Joining US DOJ Swiss Bank Program

- By : Parag Patel

…ABA conference a few days ago that 106 Swiss banks applied to the program. The exact scope of the program had previously been unknown. Swiss banks had until December 31…

Secret Swiss Bank Accounts are No Longer Secret

- By : Parag Patel

…has enshrouded Swiss banking and American involvement in it. Although many Swiss bankers maintain that privacy and bank secrecy remain intact, a Swiss newspaper called it “the start of an…

Another Swiss Bank Discloses Customer Names to the US

- By : Parag Patel

…Justice’s Swiss Bank Program. Swiss private bank BSI SA avoided prosecution for suspected tax-related offenses by paying a $211 million penalty, becoming the first bank to reach a deal in…

US Department of Justice Encourages Swiss banks to Disclose Information

- By : Parag Patel

…five banks to produce information identifying foreign banks that used ZKB’s and Butterfield’s correspondent accounts at the five banks to service U.S. clients. The Program also provides that Swiss banks…

Numerous Criminal Prosecutions of Taxpayers with Unreported Offshore Accounts

- By : Parag Patel

…business, and a private banker and executive manager at Neu Zuercher Bank (“NZB”), and Rickenbach, a Swiss attorney, were charged with aiding U.S. clients in hiding income and assets in…

Most Swiss banks participating in the US Department of Justice (DOJ) amnesty program seek extension to disclose

- By : Parag Patel

…Banque cantonale de Geneve Berner Kantonalbank Banque Cantonale Vaudoise Graubuendner Kantonalbank Banque cantonale du Jura Zuger Kantonalbank Luzerner Kantonalbank Valiant Linth Bank Coop Bank Walliser Kantonalbank Hypothekarbank Lenzburg Unlisted banks…

New voluntary disclosure program for offshore accounts in 2011

- By : Parag Patel

…actions, one being another well-known Swiss bank and one being an Asian bank (HSBC). One thing is clear, the mere fact that a taxpayer’s bank has not yet been the…

Bank Leumi: Another Foreign Bank Recommends the IRS Voluntary Disclosure Program

- By : Parag Patel

…reference to the offshore voluntary disclosure program. The bank also gave a hotline for clients. Certain foreign branches of HSBC bank have also recently sent out a similar letter to…

COURT AUTHORIZES SERVICE OF JOHN DOE SUMMONS SEEKING THE IDENTITIES OF U.S. TAXPAYERS WITH OFFSHORE ACCOUNTS AT CIBC FIRSTCARIBBEAN INTERNATIONAL BANK

- By : Parag Patel

…one bank for another bank. Financial transactions involving U.S. dollars flow through U.S. banks. Therefore, foreign banks that do business in U.S. dollars, but have no office in the U.S.,…

Full Analysis of Updated 2012 OVDP Program

- By : Parag Patel

Program While the final details of this program have not yet been announced, the IRS has described the proposed program as a potential alternative for low-compliance-risk taxpayers to become compliant….

Another Customer with Unreported Offshore Bank Accounts Pleads Guilty

- By : Parag Patel

…AG regarding allegations that the Swiss bank was helping U.S. taxpayers maintain undeclared accounts. Landegger and the Swiss Bank official discussed the possibility of entering the IRS’s offshore voluntary disclosure…

More Swiss Banks Agree to Disclose US Customers Accounts: Expect More Customer Letters to be Sent

- By : Parag Patel

…of letters are being sent to US customers with Swiss accounts held over the past 5 years. Valiant Holding, Berner Kantonalbank, and Vontobel Holding AG are the first Swiss banks…

2012 Offshore Account Criminal Tax Cases

- By : Parag Patel

…to a Swiss bank for allegedly helping U.S. taxpayers hide more than $1.2 billion in assets. Michael Berlinka, Urs Frei, and Roger Keller, along with others not named in the…

Latest Guilty Plea for an Another HSBC Offshore Bank Accountholder

- By : Parag Patel

…2008, Michael Schiavo, 53, of Westford, Mass., held an account in his name at HSBC Bank Bermuda (formerly the Bank of Bermuda, but not an NRI bank). In 2006, with…

How Will the IRS Find Out By Your Foreign Account? Let’s Count the Dozens of Ways

- By : Parag Patel

…account information. 3. Swiss Bank Program where Swiss Banks seek non-prosecution agreements and were required to disclose of your account information. The Swiss Bank Program provides a path for Swiss

Analysis of the new 2012 Offshore Voluntary Disclosure Program (OVDP)

- By : Parag Patel

Yesterday the Internal Revenue Service opened its Offshore Voluntary Disclosure Program (OVDP) to encourage more taxpayers with assets in undeclared foreign bank accounts to come forward. While the OVDP was…

Swiss Banks are Pressuring Customers to Disclose

- By : Parag Patel

bank secrecy. In August, U.S. and Swiss officials announced a comprehensive program allowing many small and medium-size Swiss banks to settle with the U.S. It doesn’t apply to about a…

Swiss Bank Disclosure Round Up

- By : Parag Patel

…Coop Bank Walliser Kantonalbank Hypothekarbank Lenzburg Unlisted banks in category 2 Union Bancaire Privee (UBP) Rothschild Bank Lombard Odier CATEGORY 3, 4 These Swiss banks have not engaged in criminal…

Avoiding and Defining Willfulness

- By : Parag Patel

…asked about foreign bank accounts on tax returns but did not report them, (2) the taxpayers never provided their Swiss bank with their home address and never told anyone but…

2016 US Dept of Justice (DOJ) Tax Division: FBAR penalty collection cases

- By : Parag Patel

…Caicos to manage his investments. The Turks and Caicos entity opened several Swiss bank accounts with Sal Oppenheim Bank, over which Pomerantz retained signatory authority. However, at the time the…

IRS Announces New 2012 Offshore Voluntary Disclosure Program (OVDP)

- By : Parag Patel

The Internal Revenue Service today reopened the offshore voluntary disclosure program to help people hiding offshore accounts get current with their taxes. The IRS reopened the Offshore Voluntary Disclosure Program

Another Bank Discloses Accountholders: Credit Suisse to Turn Over U.S. Account Data

- By : Parag Patel

…to file a traditional voluntary disclosure via the IRS VDP program that would allow them to avoid potential criminal prosecution. In February 2009, UBS AG, the biggest Swiss bank, avoided…

More Swiss Banks Agree to Cooperate with the IRS

- By : Parag Patel

Lombard Odier & Cie and VP Bank (Switzerland) last week became the latest Swiss banks to say they would work with U.S. officials in a crackdown on lenders suspected of…

2018 ABA COMMENTS ON THE OFFSHORE VOLUNTARY DISCLOSURE PROGRAM AND THE STREAMLINED PROGRAMS

- By : Parag Patel

…Streamlined Domestic Offshore Program (“SDOP”), and the Streamlined Foreign Offshore Program (“SFOP”). We co-authored the ABA comments. The comments are very constructive. It is hoped that the IRS carefully considers…

Another Foreign Bank Charged by U.S. Department of Justice

- By : Parag Patel

…of bank secrecy, the bank no longer had offices in the United States, making it less vulnerable to pressure from U.S. law enforcement authorities than other Swiss banks with a…

Swiss Banks’ Deadline to Disclose Information is Extended

- By : Parag Patel

…evade taxes to turn over information by one month. We have previously posted on the U.S. Justice Department’s program offered to Swiss banks and targeted to identifying U.S. taxpayers that…

Eleven foreign financial institutions to share their US customer account information

- By : Parag Patel

…7. Bank Leumi Le-Israel 8. Bank Hapoalim 9. Mizrahi-Tefahot Bank 10. Liechtensteinische Landesbank 11. Neue Zuercher Bank (NZB) The terms of the US government agreement would be similar to the…