The IRS has added 7 more Swiss banks to the 50% OVDP Penalty List in December, and now more than 100 Swiss banks are providing information about US taxpayers accounts and transactions directly to the IRS.  For those US taxpayers who have already come into FBAR compliance with the IRS by updating their tax returns and filing new FBARs the growing list may not impact their final settlement with the IRS.  However, US taxpayers who have yet to come into compliance with offshore account and asset reporting, the IRS is tightening their grip.  It is only a matter of time before the IRS catches up to them, promising criminal tax evasion prosecution, jail time and extremely high taxes, penalties and interest.

Everyone is pointing fingers at each other.  The brilliance of the US FATCA initiative is that it forces every player in the transaction to point a finger at everyone else, or face draconian penalties.  The banks are reporting US taxpayers to the IRS.  The IRS requires US taxpayers to list all foreign banks on their FBAR.  Members of foreign corporations or foreign trusts are required to list others whom them know to be participating or who own even the smallest of interest.  Tens of thousands of institutions worldwide are reporting information to the IRS, and US taxpayers will no longer be able to avoid the consequences.

The Banks added to the list in December are:

  • Bank J. Safra Sarasin SA (effective 12/23/15)
  • Coutts & Co Ltd (effective 12/23/15)
  • Gonet & Cie (effective 12/23/15)
  • Banque Cantonal du Valais (effective 12/23/15)
  • Banque Cantonale Vaudoise (effective 12/23/15)
  • Bank Lombard Odier & Co Ltd (effective 12/31/15)
  • DZ Privatbank (Schweiz) AG (effective 12/31/15)

Those that have already filed through the IRS OVDP or Streamlined programs and received acceptance of their applications are not subject to the penalties associated with those institutions on the IRS 50% OVDP penalty list.  They will pay the lower rate of 27.5% through OVDP if they reported accounts with an institution prior to its addition to the list.  Allen Barron is prepared to help those who have yet to file.  The protections of the attorney-client privilege safeguard our conversations and communications, allowing you to share your genuine information and activities without fear of reprisal from the IRS.

Those that fail to take advantage of the OVDP program face criminal prosecution, and the higher of $100,000 or 50% of the balance in each account for each and every violation.  US taxpayers have already been sent to jail, and many face penalties that exceed the highest balance they ever had in their offshore accounts, let alone the actual balance available today.  Come into compliance and call Allen Barron for a free and substantive consultation at 866-631-3470.


Contact an Estate Planning, Business Law Or Tax Attorney Today

To set up a free, no-obligation consultation with one of our knowledgeable San Diego based estate planning, business and tax lawyers, or learn more about our tax preparation, accounting and business advisory services call us at 866-631-3470 or contact us.