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Credit Suisse

The Swiss Finance Minister recently gave the IRS and US Department of Justice (DOJ) millions of encrypted emails between Swiss bank client advisors and their U.S. clients.  When a deal is made between the U.S. and the Swiss, the key to decoding these documents will be given to the IRS.  Among the Swiss banks involved are Credit Suisse and Clariden Leu, Americans with undisclosed offshore accounts have very little time to come forward voluntarily before the IRS opens investigations into them.

The Thorn Law Group represents U.S. taxpayers making voluntary disclosures of their offshore accounts as well as taxpayers who did not make a voluntary disclosure but are being investigated by the IRS and the Department of Justice for failure to disclose their offshore accounts.

On January 9, 2012, the IRS introduced the reopening of its Offshore Voluntary Disclosure Program for Undisclosed Offshore Accounts.  

The basic terms of the program are:

  1. A 27.5 percent penalty of the undisclosed offshore accounts based on the highest aggregate account balance over an eight-year period.
  2. Participants must pay back taxes and interest on any unreported income for up to eight years as well as accuracy related and/or delinquency penalties.
  3. Participants must file all original and amended tax returns and include payments for taxes, interest and accuracy related penalties.

Taxpayers who successfully complete the Offshore Voluntary Disclosure Program will likely avoid criminal prosecution or jail time.  They will also not be liable for taxes or penalties prior to the years disclosed in the program.

The IRS has not stated how long the 2012 Offshore Voluntary Disclosure Program will be available, and could close it at any time.

To take advantage of this rare opportunity and to potentially avoid substantial civil and criminal penalties, contact Kevin E. Thorn, Managing partner at Thorn Law Group today at ket@thorntaxlaw.com or call (202) 270-7273.

This is an area of ongoing activity by the IRS and the Department of Justice. Check out our News & Events page for the latest developments regarding undisclosed offshore accounts.

 


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