SWISS BANKS UNITE AND FIRE BACK AT THE DEPARTMENT OF JUSTICE
Neutrality is Switzerland’s unwritten motto. This devotion to conflict avoidance kept the Swiss out of two World Wars. The Swiss are known for their diplomacy, hospitality, and the ability to keep a secret. So, it came as a shock when 73 Swiss banks joined ranks to inform the U.S. Department of Justice and the IRS, […]
From the IRS with Love – What to Do When Your Foreign Bank Writes to You about Reporting Your Account under FATCA
Nothing can ruin the taste of your martini, shaken not stirred of course, than a letter from your foreign bank demanding that you report the account that you hold with them to the U.S. government. For many, this can scare The Living Daylights out of them, especially since this probably has the IRS written all […]
Deutsche Bank Becomes Latest Bank to Cooperate With DOJ In Its Swiss Tax Evasion Probe
A day doesn’t go by without a new development regarding FATCA. Friday, October 10, 2014 was no exception. That day, in an article entitled, “Deutsche Bank to Aid U.S. Justice Department in Swiss Tax Evasion Probe,” The Wall Street Journal reported that Deutsche Bank was cooperating with the U.S. Justice Department to turn over the […]
FATCA’s October 1st Numbers: Healthy or Dysmal?
Dean Byrnes recently published his monthly update on FATCA registrations in a blog entitled, “Is FATCA Failing? What do the October 1st numbers say?” Dean Byrnes breaks it all down and analyzes the statistics in a way that only he can. What you are about to read might surprise you.
Getting It Right on FATCA
In the words of the famous fictional character, Homer Simpson, “D’oh!” I made a mistake. And I’m not going to waste any time in fixing it. This isn’t the first time and it likely won’t be the last. While no one likes to make mistakes, I’ve learned from my experience as an improviser and a […]
Mad As Hell And Not Going To Take It Anymore: Two Brave Women Sue Canadian Government Over Controversial FATCA Deal
Is Ottawa violating Canadians’ constitutional rights to help the U.S. collect taxes? According to two Ontario women, it is. Two women are suing the Canadian government over a controversial deal in which Canada has agreed to share the tax information of U.S. persons who are Canadian residents with the IRS. On its face, the deal may […]
Reciprocal FATCA Reporting: Treasury Issues Proposed Rules To Enhance Financial Transparency
On July 30, 2014, the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) proposed rules requiring U.S. financial institutions to collect “Customer Due Diligence” information. The purpose of these proposed rules is to prevent unscrupulous individuals from using anonymous companies to engage in or launder the proceeds of illegal activity in the U.S. financial sector. These […]
What Should I Do If My Non-Consenting Swiss Bank Account Becomes The Target of an IRS Group Request?
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, Swiss […]
What Should I Do If I Have Received a “Declaration of Consent” Form From My Swiss Bank?
Picture this. You have an offshore account with a Swiss Bank that, for whatever reason, you haven’t gotten around to reporting on your U.S. tax return or on a FBAR. One morning, as you are sipping your coffee and checking your email inbox, you come across an ominous email from your Swiss Bank. The subject […]
A Clash of Mammoth Proportions: In One Corner, Switzerland’s Tradition of Bank Secrecy And In The Other, FATCA
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 agreements, […]