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Swiss Bank Program

Posted by: Zaher Fallahi
Posted On: Nov 14, 2015

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.  http://www.justice.gov/tax/swiss-bank-program

Zaher Fallahi, Los Angeles Tax Attorney and Orange County Tax Attorney, represents taxpayers in resolving their IRS tax problems regarding the IRS OVDP, FBAR, FATCA and tax audit.  Zaher Fallahi has been rated 10 out of 10 by Avvo  http://www.avvo.com/attorneys/90024-ca-zaher-fallahi-1955056.html , and named an Orange County top tax attorney in September 2015 http://www.ocbar.org/AllNews/NewsView/tabid/66/ArticleId/1631/Coast-Magazine-Names-OCBA-Members-Top-Attorneys.aspx  1.8% of the US lawyers are CPAs, and Zaher Fallahi is one of them. Tel: (310) 719-1040 (Los Angeles), (714) 546-4272 (Orange County), e-mail taxattorney@zfcpa.com