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Swiss Bank Porgram

The Swiss Bank Program, which was announced on August 29, 2013, provides a path for Swiss banks to resolve potential criminal liabilities in the US with respect to the accounts of US persons (US citizens, Green Card holders and other subject to the US taxation) held in Swiss banks.  Swiss banks eligible to enter the program were required to advise the department by Dec. 31, 2013, that they had reasons to believe that they had committed tax-related criminal offenses reading undeclared U.S.-related accounts.  Banks already under criminal investigation related to their Swiss-banking activities and all individuals were expressly excluded from the program.  The Tax Division made additional comments on the Swiss Bank program on November 5, 2013, and June 5, 2014.

Under this program, Swiss banks are required to:

1- Make a complete disclosure of their cross-border activities;

2- Provide detailed information on an account-by-account basis for accounts in which U.S. taxpayers have a direct or indirect interest;

3- Cooperate in treaty requests for account information;

4- Provide detailed information as to other banks that transferred funds into secret accounts or that accepted funds when secret accounts were closed;

5- Agree to close accounts of accountholders who fail to come into compliance with U.S. reporting obligations; and,

6- Pay appropriate penalties.

Swiss banks that meet all of the above requirements are eligible for a non-prosecution agreement.  Click below for the update list of non-prosecution agreement executed under the Swiss Bank Program.  Swiss Bank Program


Zaher Fallahi, Tax Attorney, CPA, licensed in California and Washington D. C., represents nationwide taxpayers with undisclosed foreign accounts before the Treasury. Telephone appointments are available for clients with undisclosed foreign accounts (civil cases only).  For an Attorney-Client Privileged Consultation, Call:

(310) 719-1040 (Los Angeles)

(714) 546-4272 (Orange County)

(877) 687-7558 Nationwide Toll Free

E-mail taxattorney@zfcpa.com


Zaher Fallahi has been rated 10 out of 10 by Avvo Rated 10 of 10 and has been named an Orange County top tax attorney  TOP Tax Attorney  1.8% of the US lawyers are CPAs, and Zaher Fallahi is one of them.