Swiss Banks To Turn Over Information To IRS!

iStock_Swiss-Bank-VaultXSmallThe Swiss government has cleared the way for a dozen banks to turn over client data to the IRS despite an earlier ruling from Switzerland’s Federal Supreme Court.

Although the IRS pushed the implementation of certain FATCA key deadlines from January 1st to July 1st, 2014, as we posted in IRS Delays FATCA Registration for Six Months, several Swiss banks are ready to turn over their records over to the IRS.

The Swiss Federal Court has dismissed protests by American clients of Credit Suisse that their account data should not be disclosed to the US Internal Revenue Service (IRS).

The IRS and Justice Department have become very adept at finding unreported offshore accounts. By targeting banks and individual bankers, the IRS is often able to leverage the threat of jail in return for cooperation and the release of customer records. The IRS also has several other tools in its arsenal.

On Tuesday, June 18, 2013, we posted DOJ Requests Identification of US Depositors in Bank Weglin – Time To Come Clean? where we discussed that the US Department of Justice has submitted another administrative assistance request to the Swiss authorities, this one demanding the identification of American clients of the private bank Wegelin who were beneficiaries of asset management companies between 2002 and 2012.

Two weeks previous to this Bank Wegelin, the private bank Julius Baer was also notified that it was subject of a similar request.

U.S. authorities have more than a dozen banks under formal investigation, including:

  •  Credit Suisse,
    •  Julius Baer,
    •  the Swiss Branch of HSBC,
    •  Pictet and Zuercher Kantonalbank and
    •  Basler Kantonalbank.

Many U.S. taxpayers have been sitting on the fence waiting to see what happens with FATCA or the outcome of this case. That could prove to be a very costly mistake!

Once your name is turned over to the government, its probably too late to take advantage of any of the amnesty programs. Customers with accounts at Israel based Bank Leumi learned that lesson the hard way.

Because the IRS operates it’s amnesty programs on a “first contact” basis, its important to approach the IRS before they find you or before your name is turned over.

Mr. Marini concentrates his practice in Representation before the IRS and All Other Tax Authorities, IRS Collections, Offers in Compromise, Installment Payment Plans, Appeals, Sales Tax Audits, International and Tax Law, Asset Protection and Estate Planning.

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