Offshore Disclosure — The Options

For the last several years, the IRS has made a concerted push to crackdown on undisclosed offshore accounts and foreign assets.  The bottom line is of course to recover unpaid taxes.  These efforts have been strengthened recently by agreements reached between the IRS and offshore financial institutions and governments.  These agreements largely stem out of…

Swiss Banks Receive Fresh Round of Information Requests

The US Department of Justice has sent information requests to forty Swiss banks taking part in an information sharing program between the US and Switzerland.  This program evolved out of the 2010 Foreign Account Tax Compliance Act (FATCA) which provides from automatic information sharing between foreign financial institutions and the US government regarding the accounts…

IRS Crackdown Expands With New Penalty For Banks

Today a key provision of the Foreign Account Tax Compliance Act (FATCA) goes into effect.  The 2010 law aims to combat tax evasion accomplished through offshore accounts by setting up information sharing agreements between the IRS and foreign financial institutions or foreign governments.  To date more than 80 jurisdictions have reached such agreements with the…