Update for Clients with Offshore Accounts: U.S. and Switzerland Reach Agreement on Tax Evasion Investigations
By Matthew Porter, Esq., LL.M
The tax attorneys at Nardone Law Group are tracking the latest developments in the IRS and U.S. Department of Justice’s continued efforts to combat offshore tax evasion. The U.S. Government’s efforts in criminally prosecuting offshore tax evasion has highlighted the importance of understanding the IRS’s Offshore Voluntary Disclosure Program (the “OVDP”). On August 29, 2013, the United States and Switzerland reached an agreement that severely punishes Swiss banks that allowed U.S. citizens to shelter their money in offshore accounts. The tax attorneys at Nardone Law Group view this agreement as yet another significant step by the U.S. government to aggressively enforce international tax compliance and punish offshore tax evasion, highlighting the importance of programs such as the IRS’s Offshore Voluntary Disclosure Program, or the OVDP.
U.S. Government Criminally Prosecuting U.S. Citizens with Undisclosed Swiss Accounts
The agreement with Switzerland provides the U.S. Government greater access to secret offshore accounts so that it can criminally prosecute those who have violated international tax law. According to Deputy Attorney General James M. Cole, “This program will provide us with additional information to prosecute those who used secret offshore bank accounts and those here and abroad who established and facilitated the use of such accounts.” Mr. Cole further indicates that “Now is the time for all U.S. taxpayers who hid behind Swiss bank secrecy laws or have undeclared offshore accounts in other foreign countries to come forward and resolve their outstanding tax issues with the United States.”
Further, the U.S.-Swiss agreement encourages Swiss banks to cooperate in the Department of Justice’s continuing investigations of the use of foreign bank accounts to commit tax evasion. Switzerland will also encourage its banks to participate in the program. If you have hidden assets in an offshore account in Switzerland, it is extremely important to discuss your options with an experienced international tax lawyer. Effectively reporting to the IRS can be a daunting and intimidating undertaking. But, the IRS’s Offshore Voluntary Disclosure Program—or the OVDP—can be very beneficial for noncompliant U.S. taxpayers to come forward while limiting their risk of criminal prosecution.
U.S. Taxpayers May Utilize the IRS’s Offshore Voluntary Disclosure Program (OVDP) to Report Hidden Swiss Accounts
Although the U.S. Government is continuing to criminally prosecute U.S. citizens who have unreported foreign accounts, the IRS provides an opportunity to come forward and report those accounts through the OVDP. The OVDP enables noncompliant U.S. taxpayers the opportunity to resolve their tax liabilities while minimizing their chances of criminal prosecution. If you have questions about the IRS’s OVDP, you should contact an experienced international tax lawyer to discuss your options in reporting your hidden offshore accounts.
Contact Nardone Law Group
The tax attorneys at Nardone Law Group routinely advise clients in Columbus, Ohio and throughout the United States about their federal tax obligations and ways to comply with federal tax law, including compliance with laws governing foreign accounts. The recent U.S.-Swiss agreement highlights the importance of understanding your offshore account filing requirements and the IRS’s OVDP. If you have questions about your federal tax obligations, foreign accounts, or the OVDP, you should contact an experienced tax attorney. Our experienced tax lawyers will thoroughly review your case to determine what options and alternatives are available. Contact us today for a consultation to discuss your case.