US-SWISS VOLUNTARY DISCLOSURE PROGRAM: DEADLINES ARE LOOMING – SWISS BANKS NEED NOT PANIC, BUT MUST ACT SWIFTLY AND THOUGHTFULLY -
The recently announced voluntary bank disclosure program between Switzerland and the...more
The recently announced voluntary bank disclosure program between Switzerland and the US offers worried Swiss banks the possibility of peace of mind from future prosecution. The question now confronting Swiss banks is whether...more
The IRS has released Notice 2013-69, including a draft FFI Agreement and several intended updates to the existing Treasury Regulations implementing the Foreign Account Tax Compliance Act (FATCA).
In recent years, the US Department of Justice has been aggressively investigating the use of bank accounts outside the US to evade tax. While emphasizing that its enforcement activities are and must remain global, the DOJ has...more