Oldest Swiss Bank Indicted for Tax Fraud

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.

Today, the IRS announced that they reopened the Offshore Voluntary Disclosure Program for taxpayers with undeclared foreign accounts.

On January 3, 2012, the U.S. Attorney’s Office for the Southern District of New York charged three Swiss bankers with hiding more than $1.2 billion in U.S. taxpayer accounts from the IRS. The announcement was made by Preet Bharar, the Manhattan U.S. Attorney.

IRS has put in place a program aimed at auditing taxpayers who did a so called “quiet disclosure” — those who chose not to make a voluntary disclosure, but rather chose to quietly file amended tax returns and FBARs.

The Internal Revenue Service released details of its plan to show some leniency on the penalties for failure to file tax returns and Foreign Bank Account Reports for the American citizens living abroad.

Credit Suisse AG, the second largest bank of Switzerland, has notified some of its U.S. clients that it will disclose their identities and account details to the Internal Revenue Service.

Swiss government has apparently proposed a multibillion-dollar settlement with the U.S. in response to the allegations that it helped American taxpayers avoid billions of dollars in U.S. taxes.

The Internal Revenue Service announced that 12,000 new applications came in from the 2011 Offshore Voluntary Disclosure Initiative (OVDI) program that closed last week. This pushed the total to 30,000 since the program began in 2009.

The IRS has extends the deadline for the 2011 Offshore Voluntary Disclosure Intitiative (OVDI) to September 9, 2011 (from the original date of August 31, 2011). Further, the IRS has clarified what information needs to be provided by September 9, 2011, in the event that all the documents required under the OVDI are not ready to be provided by that date.