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.

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.

The IRS is reminding taxpayers that the deadline for the 2011 Offshore Voluntary Disclosure Initiative (OVDI) will expire on August 31, 2011.

Indian-Americans seek review of FBAR rules and the IRS’ 2011 Offshore Voluntary Disclosure Initiative.

In Notice 2011-54, the IRS has extended the deadline for persons who have signature authority over, but no financial interest in, foreign financial accounts to file Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR). They now have until November 1, 2011, to report their signature authority over such accounts during 2009 and earlier years. The deadline for 2010, however, remains unchanged at June 30, 2011.

IRS Posts New Frequently Asked Questions for the 2011 OVDI Program