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Neue Zuercher Bank

The IRS and US Department of Justice (DOJ) are actively investigating the Swiss bank Neue Zuercher Bank (NZB) following the 2009 indictment of a NZB bank executive on charges he assisted US taxpayers in committing tax fraud through use of undisclosed offshore accounts in Switzerland.

As part of its negotiations with the U.S., Swiss authorities have provided U.S. officials with tens of thousands of pages of encrypted data containing information to identify U.S. taxpayers with offshore accounts at Neue Zeurcher Bank and other Swiss banks.  As soon as the U.S. and Swiss reach agreement, the Swiss authorities will decode the data and the IRS and DOJ will begin investigating those U.S. taxpayers.  U.S. taxpayers with offshore accounts or other property should ensure that their foreign accounts and assets are properly reported to the IRS or face steep financial penalties and criminal charges.  Taxpayers who have not disclosed their accounts to the IRS are encouraged to disclose their offshore accounts to the IRS through the voluntary disclosure program.

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 its 2012 Offshore Voluntary Disclosure Program for taxpayers with 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 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 ket@thornlawgroup.com 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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