Following the 2009 indictment of a Neue Zuercher Bank (NZB) executive, based on charges that the bank executive assisted U. S. taxpayers in committing tax fraud, the United States Department of Justice (DOJ) and the Internal Revenue Service (IRS) have begun actively investigating NZB.
Thousands of pages of encrypted data between client advisors of Swiss banks and their U.S. clients have been turned over to the DOJ and the IRS. As soon as the U.S. and the Swiss reach an agreement, Swiss authorities will decode the data and the DOJ and the IRS will begin investigating those U.S. taxpayers with undisclosed offshore accounts.
U.S. officials introduced the 2012 Offshore Voluntary Disclosure Initiative to urge U.S. taxpayers with undisclosed offshore accounts to come into compliance in order to avoid severe civil penalties and IRS criminal investigations.
Terms of the 2012 IRS Voluntary Disclosure Program include:
- A 27.5 percent penalty of the undisclosed offshore accounts based on the highest total account balance over an eight-year period of each account.
- Taxpayers participating in the 2012 Voluntary Disclosure Program must pay back interest and taxes on any unreported income for up to eight years, as well as delinquency and/or accuracy related penalties.
- Taxpayers with undisclosed offshore accounts must file all amended and original tax returns, in addition to the payments for taxes, interest, and accuracy related penalties, as mentioned above.
The attorneys of Thorn Law Group are experienced in representing U.S. clients who are making voluntary disclosures of their overseas bank accounts through the 2009, 2011, and 2012 Amnesty Initiatives.
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