Julius Baer

The IRS and US Department of Justice (DOJ) are continuing their investigation into Swiss bank Julius Baer as part of their on-going probe of Swiss banks who allegedly helped US taxpayers commit tax fraud through use of undisclosed offshore accounts in Switzerland.

As part of its negotiations with the US, Swiss authorities have provided US officials with tens of thousands of pages of encrypted data containing information to identify US taxpayers with offshore accounts at Julius Baer and other Swiss banks.  As soon as the US and Swiss governments reach agreement, the Swiss authorities will decode the data and the IRS and DOJ will begin investigating those US taxpayers.  Now is the time for US taxpayers with offshore accounts or other property to ensure that their foreign accounts and assets are properly reported to the IRS or face steep penalties and criminal charges when their information is disclosed to the IRS by the Swiss. Taxpayers who have not disclosed their offshore accounts to the IRS are encouraged to enter the voluntary disclosure program.

On January 9, 2012, the IRS announced its 2012 Offshore Voluntary Disclosure Program for taxpayers with undisclosed offshore accounts.

The Thorn Law Group represents U.S. taxpayers making voluntary disclosures of their offshore accounts as well as tax payers 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.

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 the past 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 opportunity and to potentially avoid substantial civil and criminal penalties, contact Kevin E. Thorn, Managing partner at Thorn Law Group today at or call 201-355-8202.

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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