The program for non-prosecution agreements for Swiss Banks is
largely settled. However, in a ruling by the Swiss Courts a few
weeks ago, a bank in the Canton of Ticino was prohibited from
releasing the names of two Swiss attorneys who acted as proxies for
American customer accounts. Further, the name of a law firm who
assisted U.S. persons was also withheld.
The participating bank was in the process of complying with
the Settlement Program and it intended to release the names of the
lawyers and law firm as part of the disclosure process, but a suit
followed to block the release of the information.
Ultimately, the Swiss court held that the names should be
protected from disclosure under its laws. The Court also found that
the U.S. lacks similar legislation to provide adequate data
Last week, U.S. authorities have indicated that by mid-November
an expanded list of banks and facilitators would be published. That
list mandates a 50% penalty, as opposed to a 27.5% penalty, for
U.S. persons entering the Offshore Voluntary Disclosure Program.
For those U.S. persons who have not yet come into compliance with
their U.S. tax obligations, time is growing short.
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The IRS has announced that it will cease the processing of paper returns at three IRS campuses over the coming years. The three affected locations are Covington, Kentucky, Fresno, California, and Austin, Texas.
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