International Taxation

What Should I Do If My Non-Consenting Swiss Bank Account Becomes The Target of an IRS Group Request?
Listen Suppose that you have an undisclosed offshore account with XYZ Bank, a Swiss bank. You received a declaration of consent from XYZ Bank requesting your consent to disclose your account information to the IRS directly. You refused. Because you did not consent, your account became subject to aggregate reporting by XYZ Bank. Pursuant to the Swiss-U.S. FATCA Agreement, …
A Clash of Mammoth Proportions: In One Corner, Switzerland’s Tradition of Bank Secrecy And In The Other, FATCA
Listen While the Swiss banking system’s reputation for hiding numbered bank accounts under a cloak of anonymity was once considered sacrosanct, the seal was broken on its banking secrecy back in 2013 when it signed an international agreement with the OECD (Organization for Economic Cooperation and Development) to fight tax evasion.  Since then, other international …
The End of Swiss Banking Secrecy?
Listen “There is only one thing in the world worse than being talked about, and that is not being talked about.”[1]  Oscar Wilde’s insightful observation about humankind’s proclivity toward public recognition does have exceptions.  For a variety of reasons, men and women throughout the world have often sought confidentiality in their financial affairs, chiefly through …
Lowering the Bar for Willfulness for FBAR Penalties
Listen The IRS has authority to assert FBAR civil penalties.  Before delving into the FBAR abyss, this is a good time to debunk some FBAR myths.  First, there is no such thing as an FBAR penalty within the Offshore Voluntary Disclosure Program (OVDP).  The FBAR penalty exists only outside of the OVDP framework.  However, there …