We frequently represent taxpayers before the Internal Revenue Service (“IRS”) in all types of civil and criminal tax controversies, including foreign bank account issues. It is now being widely reported that the Swiss banks will probably settle a sweeping U.S. probe of offshore tax evasion by paying billions of dollars and handing over names of thousands of Americans who have secret accounts, according to two people familiar with the matter.
Bloomberg is reporting that U.S. and Swiss officials are concluding negotiations on a civil settlement amid U.S. criminal probes of 11 financial institutions suspected of helping American clients hide money from the IRS according to five people with knowledge of the talks who declined to speak publicly because they are confidential.
The Swiss government seeks to outline a final accord for the Foreign Affairs Committee of its Parliament’s upper house on Nov. 10, according to a person familiar with the matter. The number of banks that will pay to resolve the U.S. negotiations may extend beyond the 11 under criminal investigation, the people said.
Under accords this year with Germany and the U.K. on untaxed assets, the identity of clients remained secret. The U.S. insists that the Swiss disclose client account data, and the banks may end up handing over data on 5,000 to 10,000 accounts, the people said. A final determination hasn’t been made, they said.
The U.S. Justice Department also may bring criminal charges or civil enforcement actions against any of the 11 financial institutions. They could avoid prosecution by separately paying fines, admitting wrongdoing and disclosing data, the people said. On Aug. 30, the Justice Department requested statistical data from the 11 about their U.S. accounts, which the U.S. has received and is analyzing, the people said.
The IRS ran two voluntary disclosure programs in 2009 and 2011 to prompt United States Taxpayers to come forward and disclose their foreign bank accounts, pay a modified fine and bring the money back into the tax system. For those taxpayers who have failed to do so, voluntary disclosure is still available and we urge you to contact us and come forward before the IRS finds you.
So whether you live in Stamford, Connecticut or elsewhere, if any issue arises for foreign bank accounts or any other IRS issue, please feel free to contact me at (203) 602-5550 or by email at firstname.lastname@example.org
Eric L. Green, Esq.
Convicer, Percy & Green, LLP
60 Long Ridge Road, Suite 202
Stamford, CT 06902
Ph. (203) 602-5550
Fax (203) 286-1311