IRS Announces Modifications to Offshore Voluntary Disclosure Program

The IRS has amended their Offshore Voluntary Disclosure Program to require that the Taxpayer pay a 50% penalty (instead of the previous 27.5%) of the account balance at the time of the OVDP application if the financial institution where they maintained the account is under IRS or Dept. of Justice Investigation. The following Swiss Banks are under IRS/Dept of Justice criminal investigation:

1. Credit Suisse (settled 5/14)
2. Zurich Cantonal Bank
3. Pictel
4. Julius Baer
5. Basil Cantonal Bank
6. Wegelin(closed 2013)
7. Rahn and Bodmer
8. Neue Zurcher Bank (closed 2011)
9. Neue Private Bank
10. Bank Frey(closing announced 10/13)
Additionally, Swiss Branches of foreign banks:
11. HSBC(Britain)
12. Liechtenstein Landesbank(branch closing)
13-15. Israeli Banks: Leumi, Hapaolim, Mizrahi

Please see:
Important Links To Latest IRS OVDP Procedures
by Charles Rettig, Contributor, Forbes.com

On June 18 in the IRS announced important modifications to the 2012 Offshore Voluntary Disclosure Program (OVDP) and an expansion of the offshore related Streamlined Filing Compliance Procedures (SFCP) announced in 2012.

Changes to the OVDP include requiring taxpayers to submit all account statements and pay the offshore penalty at the time of the OVDP application. Further, the offshore penalty increases from 27.5% to 50% if, before the taxpayer’s OVDP pre-clearance request is submitted, it becomes public that the financial institution where the underlying financial account is maintained is under investigation by the IRS or the Department of Justice. Further, beginning on August 4, 2014, any taxpayer having an undisclosed interest in an account maintained at certain listed foreign financial institutions listed at irs.gov will be subject to a 50% miscellaneous offshore penalty if they submit a pre-clearance letter to the IRS Criminal Investigation.

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