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Monthly Archives: September 2012

The U.S. Exchange of Information & FATCA

The U.S. Treasury has indicated that the lack of a double tax treaty or tax information exchange agreement will not prevent a jurisdiction from entering into a FATCA Intergovernmental Agreement with the U.S. as the U.S. would be willing to sign an IGA and a TIEA at the same time.

The U.S. exchange of information network is shown on the table Below. This information is provided by the OECD and jurisdictions may have signed further agreements that are not reflected.
 

Source :

FSI Tax Post

Read more at: Tax Times blog

Your Last Chance To Report your Offshore Account!

Yesterday we  posted More Swiss Bank Files Being Transferred to the IRS! - where we discussed that Credit Suisse AG has handed over more internal documents to U.S. authorities.

"The documents concerned comprise e-mail correspondence, including attachments, with clients domiciled in the U.S., as well as internal e-mail correspondence, including attachments, about clients domiciled in the U.S. and the U.S. cross-border business in general during the period from June 2001 to March 2011."

Other banks that confirmed that they sent documents, including employee names, to the U.S. are the private-banking unit of HSBC Holdings, Julius Baer Group AG, Zuercher Kantonalbank and Basler Kantonalbank.

So if you are US taxpayer who had an account with one of theses Swiss Banks and you have not made a voluntary disclosure, YOU ARE ABOUT TO BE DISCOVERED! 

Technically, once the IRS has obtained your identity from these records, you do not qualify for voluntary disclosure.

The mere fact that the Service served a John Doe summons, made a treaty request or has taken similar action does not make every member of the Joe Doe class or group identified in the treaty request or other action ineligible to participate.

However, once the Service or the Department of Justice obtains information under a John Doe summons, treaty request or other similar action that provides evidence of a specific taxpayer's noncompliance with the tax laws or Title 31 reporting requirements, that particular taxpayer will become ineligible for OVDP and Criminal Investigation's Voluntary Disclosure Practice.

For this reason, a taxpayer concerned that a party subject to a John Doe summons, treaty request or similar action will provide information about him or her to the Service should apply to make a Voluntary Disclosure as soon as possible.

If you have Unreported Income From Swiss Banks or are a Swiss Bank Employee named in these documents, contact the Tax Lawyers at Marini & Associates, P.A. for a FREE Tax Consultation at www.TaxAid.us or www.TaxLaw.ms  or Toll Free at 888-8TaxAid (888 882-9243).


 

Read more at: Tax Times blog

Swiss Bankers Expecting Large Cash Outflows

UBS has confirmed that the Swiss banking industry is expecting large cash outflows due to the recently agreed bilateral withholding tax treaties with Germany, Austria and the UK. Switzerland's second largest bank Credit Suisse made similar remarks last week.

UBS expects Swiss banks to see European clients withdraw "hundreds of billions of francs" as a result of steps to stop foreigners using secret accounts to evade taxes. 
Juerg Zeltner, head of UBS wealth management, reiterated an estimate he gave in May that Switzerland's biggest bank could see outflows of 12-30 billion Swiss francs ($12.8-31.9 billion) from total European assets under management of over 300 billion. 
German financial services consultancy Zeb/Rolfes Schierenbeck Associates estimates Swiss banks could see European clients pull up to 200 billion francs by 2016 of the 789 billion it believes they currently hold in untaxed assets.
Putting the potential outflows in context, Zeltner said UBS had seen about 200 billion francs of withdrawals during the financial crisis, when the bank had to be rescued by a government bailout after huge subprime losses. Client assets fell almost double that amount due to market and currency moves.

Swiss bank secrecy - which has helped the country build a $2 trillion offshore financial centre dominated by UBS and Credit Suisse - has come under heavy fire in recent years as cash-strapped governments elsewhere have sought to fight tax evasion.

If you have Unreported Income From Swiss Banks, contact the Tax Lawyers at Marini & Associates, P.A. for a FREE Tax Consultation at www.TaxAid.us or www.TaxLaw.ms or Toll Free at 888-8TaxAid (888 882-9243).

 
 
 
Source:

 

Read more at: Tax Times blog

More Swiss Bank Files Being Transferred to the IRS!

Credit Suisse AG is handing over more internal documents to U.S. authorities in response to Washington's crackdown on tax evasion, according to one of its internal memos.

All client-specific data have been removed from the business records that will be transferred, as they were from the first batch of records. The employees whose names are in the data aren't suspected of having helped Americans avoid taxes.

A spokesman for Credit Suisse confirmed their interal memo invites staff members who aren't sure whether their names will be included in the coming transfer to contact a help desk for more information.

Employees will now be informed in advance when information containing their names is transferred to U.S. authorities. The changes were outlined in a recent internal memo to employees and were agreed to in cooperation with the Swiss Federal Data Protection and Information Commissioner.

"The documents concerned comprise e-mail correspondence, including attachments, with clients domiciled in the U.S., as well as internal e-mail correspondence, including attachments, about clients domiciled in the U.S. and the U.S. cross-border business in general during the period from June 2001 to March 2011," Hans-Ulrich Meister, who heads Credit Suisse's private-banking unit, told staff in the memo.

The latest records scheduled for transfer to the U.S. include names of employees of Credit Suisse's private-banking division who served clients in relation to business with the U.S.

All client-specific data have been removed from the business records that will be transferred, as they were from the first batch of records. The employees whose names are in the data aren't suspected of having helped Americans avoid taxes.

Employees whose names were included in a first batch of data sent to the U.S. said they felt betrayed and some said they were worried that they risk being arrested or questioned if they travel to the U.S.

Other banks that confirmed that they sent documents, including employee names, to the U.S. are the private-banking unit of HSBC Holdings, Julius Baer Group AG, Zuercher Kantonalbankand Basler Kantonalbank.

If you have Unreported Income From Swiss Banks or are a Swiss Bank Employee named in these documents, contact the Tax Lawyers at Marini & Associates, P.A. for a FREE Tax Consultation at www.TaxAid.us or www.TaxLaw.ms or Toll Free at 888-8TaxAid (888 882-9243).

Source:

Wallstreet Journal

 

Read more at: Tax Times blog