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Swiss Banks Seek Negotiated Tax Settlement Amid Reports of U.S. ‘Ultimatum' on Details

Swiss banks are urging their government and the United States to reach a negotiated solution to their dispute over U.S. funds hidden away in Swiss banks, amid reports the U.S. Department of Justice has issued an “ultimatum” on the handover of information on undeclared accounts of U.S. taxpayers with Swiss banks.

According to Swiss media, over the weekend of Sept. 3, U.S. Deputy Attorney General James Cole wrote a letter Aug. 31 to the Swiss government insisting that Swiss authorities hand over information on hidden U.S. funds in the country by Sept. 6. The letter specifically targeted Credit Suisse, the country’s second largest bank, as well as nine other private and regional banks, according to the reports.

Swiss media also that the Swiss financial industry regulator, was collecting information from the banks on all deposits by U.S. taxpayers of $50,000 or more between 2002 and July 2010.

Now that the implementation of FATCA has been postponed to the middle or end of 2013, the DOJ is reverting back to the process of requesting/summonsing information from other Swiss Banks; similar to its 2009 program which they successfully used against UBS; where the Swiss government was forced to eventually hand over detailed information on the accounts of U.S. taxpayers with the country’s largest bank.

Read more at: Tax Times blog

IRS Releases Final Form 706 for Estate Tax Application in 2010

The Internal Revenue Service Sept. 3 released a final 2010 Form 706, United States Estate (and Generation-Skipping Transfer) Tax Return, to be filed for decedents who died in 2010.

Form 706 is one of two that will be used by estates choosing between the modified carryover basis regime and the estate tax for property transferred from a decedent in 2010. The instructions for the form have not yet been released.

Form 706 is available at

Read more at: Tax Times blog

New regulations provide that a evidence of a postmark is not sufficient to prove delivery

New regulations provide that a evidence of a postmark is not sufficient to prove delivery. ( T.D. 9543, 76 Fed. Reg. 52561 (8/23/11), amending Regs. §301.7502-1, by revising paragraphs (b)(2) and (e) and adding paragraphs (c)(3) and (g)(4)).

If a tax return preparer files returns, the preparer should either hand-deliver them to the IRS, use certified mail, or use an alternative described below.

When a preparer sends returns to clients, the preparer must consider not only recommending that the clients send the returns via certified mail but also:
• warn the clients that the failure to use certified mail might invalidate the returns, and
• encourage the clients to contact the preparer for alternative methods if certified mail does not work for the clients.

Private delivery services, such as UPS or FedEx, can also be used, but you should first confirm by looking at Notice 2004-83 , 2004-52 I.R.B. 1030 or any relevant guidance issued after that.
The IRS stated that it will be issuing more guidance on private delivery services.

Read more at: Tax Times blog

Whatcha Gonna Do When They Come for You? IRS CID Stepping Up its Act

WASHINGTON –The Internal Revenue Service’s (IRS) Criminal Investigation (CI) division surpassed its goals for Fiscal Year (FY) 2010, according to a new report publicly released by the Treasury Inspector General for Tax Administration (TIGTA).

CI is primarily dedicated to developing and investigating legal source tax cases, which are crimes involving legal industries and occupations and legally earned income. The prosecution of these cases is key to supporting the IRS’s overall compliance goals, enhancing voluntary compliance with the tax laws, and promoting fairness and equity in the tax system. The overall objective of TIGTA’s review was to provide a statistical portrayal with trend analyses of CI’s enforcement activities for Fiscal Years 2006 through 2010.

For more information go to

Read more at: Tax Times blog