Credit Suisse has provided U.S. investigators with the information related to U.S. account holders.

This case is another example of the government’s efforts to crack down on the offshore tax evasion and enforce FBAR rules. Although not every case where a foreign bank account was not properly reported bears a high risk of criminal prosecution, those type of situations are very sensitive and taxpayers with undeclared foreign bank accounts are encouraged to consult tax attorneys in order to evaluate their options.

New IRS Rules will require U.S. banks to report interest payments to nonresident aliens starting January 1, 2013.

The Treasury’s Financial Crimes Enforcement Network (FinCEN) has announced that electronic filing (e-filing) of TD F 90-22.1, Report of Foreign Bank and Foreign Accounts (FBAR), won’t be required until June 30, 2013.

Those taxpayers who are not U.S. citizens, and are convicted of filing a false tax return under Internal Revenue Code section 7206(1), may be deported from the United States.

IRS Issues Foreign Account Tax Complianec Act (FATCA) Proposed Regulations

IRS announces rules for automatic acceptance of installment agreements for balances up to $50,000 for payment terms of up to 6 years.

Oldest Swiss Bank Indicted for Tax Fraud

In the recently issued Notice 2012-8, the IRS proposed a new Revenue Procedure that would revise the threshold requirements for requesting equitable innocent spouse relief. The proposed Revenue Procedure would revise the factors used by the IRS in evaluating requests for innocent spouse relief submitted under Code Sec. 6015(f) when the facts and circumstances warrant. The guidelines would ensure that, when appropriate, requests are granted in the initial stage of the administrative process.

The National Taxpayer Advocate (NTA) has issued a Taxpayer Advocate Directive , complaining about unfair treatment of certain participants in the 2009 Offshore Voluntary Disclosure Program (OVDP). It appears that the NTA shared the same frustration with the OVDP that many tax practitioners, including our tax attorneys, have felt over the infamous Q&A 35 published by the IRS in the Frequently Asked Questions and Answers for the 2009 program.