Criteria For Disclosure Of Swiss Accounts Announced: Now That The Offshore IRS Voluntary Disclosure Has Ended, What's A Taxpayer To Do?


The U.S. Department of Justice recently revealed the criteria for disclosure of account information made in the August 19, 2009, U.S.-Swiss Treaty Request, under the U.S.-Swiss tax treaty. This disclosure comes on the heels of the passage of the deadline for applying for the U.S. Internal Revenue Service's ("IRS") Offshore Voluntary Disclosure Program ("OVDP"), for offshore financial accounts. For those who timely applied for the OVDP, much remains to be done to complete the voluntary disclosure process. Securing bank records, preparing amended tax returns and Reports of Foreign Bank and Financial Accounts ("FBARs") are only part of the process to complete the voluntary disclosure. For those who missed the deadline, opportunities are still available to avoid criminal prosecution and resolve civil liabilities for offshore and domestic tax compliance issues under the long-standing IRS voluntary disclosure practice.

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