There are very few safe tax havens left in the world, and the vast majority of the Swiss financial houses, banks and investment management companies are providing the IRS with direct feeds on US taxpayer accounts. This information includes account information, balances, and transactional data. The Swiss institutions have agreed to provide all of this information to the IRS in order to preserve access to US markets. The US Justice Department applied criminal pressure to offshore banks and investment houses using FATCA, and the results are clear: The Swiss are no longer a safe tax haven for US taxpayers.
If you have offshore bank accounts, investments or assets the time is now to come clean with the IRS, and make a full financial disclosure utilizing either the Offshore Voluntary Disclosure Program or OVDP, or the Streamlined Domestic (Foreign) Offshore Procedures and come into full FBAR compliance with the IRS. Recent developments and changes to the Streamlined Application forms makes it very clear that the IRS is not going to accept a simple assertion by the tax payer that their failure to report offshore income, assets and accounts was “non-willful.” The new forms require detailed personal background information, education, financial investment history, source fund proofs and a comprehensive story of the purpose for the investment and how it was selected by a US taxpayer, all under penalty of perjury. Ignorance is clearly not an acceptable excuse.
If a taxpayer attempts to file under the streamlined program and is rejected by the IRS, they will face the full fury of maximum penalties and interest and criminal prosecution and jail time for tax evasion. If you are a US taxpayer with unreported or under-reported offshore investment and banking activities, or if you have been convinced that a foreign trust is the best vehicle for reducing taxes it is important that you contact Allen Barron’s experienced international tax attorneys for a free consultation at 866-631-3470. The vast majority of the Swiss financial houses, banks and investment management companies are providing the IRS with direct feeds on US taxpayer accounts and you need to protect your interests and assets.
