The number of banks who have signed a disclosure agreement with the IRS expands monthly, and more than 100 Swiss banking institutions alone have been added to the IRS list of 50% OVDP penalty banks. Even more Swiss banks are in the process of completing their negotiations with the US, and will soon come into compliance with Foreign Account Tax Compliance Act or FATCA and be added to the list.
We are concerned with the number of US taxpayers who have filed the Streamlined Option of the Offshore Voluntary Disclosure Program or OVDP in order to obtain the lower penalty threshholds. The IRS has clearly established that this program will only apply to a limited number of taxpayers who have exhibited “non-willful” conduct as it applies to foreign bank accounts, investments, real estate and other asset reporting requirements of the Foreign Bank Account Report or FBAR.
If your bank appears on the IRS list, you will pay a mandatory penalty of 50%, unless your streamlined application cleared prior to the addition of the bank to the list. There are serious doubts about those who have filed for the streamlined option, who have banks that appear on the IRS 50% penalty list. There is a substantial risk that they will be rejected from the program and face the highest penalties and the genuine risk of going to jail for tax evasion.
These are serious issues, and the IRS continues to make examples of US taxpayers who have hidden income and assets offshore for years. The extent of information pouring into the IRS from foreign financial institutions is a boon to IRS tax collection efforts. The time to come into compliance is now. We invite you to call 866-631-3470 for a free and substantive consultation.
