On September 29, 2018, the Internal Revenue Service closed for good the long-running Offshore Voluntary Disclosure Program (OVDP), its hugely successful tax amnesty program for undisclosed offshore financial assets. Since March 2009, the IRS has maintained an offshore voluntary disclosure program in some form or fashion, and more than 56,000 taxpayers have taken advantage of
USDOJ Swiss Bank Program
On Eve of “Paradise Papers” Release, At-Risk Individuals Should Consider Immediate Action to Mitigate Potential for Criminal Prosecution
Tomorrow morning (November 17) the International Consortium of Investigative Journalists (ICIJ) is set to release publicly the first set of comprehensive data from the recent “Paradise Papers” leak. The initial data will include information on approximately 25,000 offshore entities and trusts registered in more than 30 jurisdictions, primarily from client records of the Appleby law…
DOJ Offshore Bank Resolution Offers Cooperation Road Map
August 29, 2017 – Law360
The U.S. Department of Justice revealed its latest offshore bank resolution by announcing that it had entered into a nonprosecution agreement with a Swiss asset management firm called Prime Partners SA. This means that Prime Partners will not be criminally prosecuted for participating in what prosecutors characterized as a conspiracy
…
Justice Department’s Latest Offshore Bank Resolution Confirms Value of Self-Disclosure and Voluntary Remediation by At-Risk Foreign Institutions
The Justice Department revealed its latest offshore bank resolution by announcing that it had entered into a non-prosecution agreement with a Swiss asset management firm called Prime Partners. This means that Prime Partners will not be criminally prosecuted for participating in what the DOJ characterized as a conspiracy to defraud the Internal Revenue Service and…
DOJ Announces Final Resolutions Under Its Groundbreaking Swiss Bank Program As Program Enters “Legacy” Phase
Originally published by the International Enforcement Law Reporter (Feb. 10, 2017)
By Matthew D. Lee[1]
On December 29, 2016, the Justice Department’s Tax Division announced that it had reached final resolutions with the remaining “Category 3 and 4” Swiss banks that had enrolled in the Swiss Bank Program.[2] Originally unveiled in August 2013,…
DOJ Announces Final Resolutions Under Its Groundbreaking Swiss Bank Program As Program Enters “Legacy” Phase
Today the Justice Department’s Tax Division announced that it has reached final resolutions with the remaining “Category 3 and 4” Swiss banks who had enrolled in the Swiss Bank Program. Originally unveiled in August 2013, the Swiss Bank Program provided a path for Swiss banks to resolve potential criminal liabilities in the United States,…
IRS Adds Nearly 50 New Names to OVDP Facilitator List, Effective November 15
Effective today, 47 new names have been added to the Internal Revenue Service’s ever-expanding list of “Foreign Financial Institutions or Facilitators” which trigger a significantly higher penalty for participants in the Offshore Voluntary Disclosure Program (OVDP). Under the current OVDP terms, individuals making a voluntary disclosure about offshore bank accounts and assets can…
Internal Revenue Service Announces Major Milestone in Offshore Tax Crackdown
The Internal Revenue Service has achieved another milestone in its long-running campaign to crack down on offshore tax evasion, announcing that more than 100,000 taxpayers have voluntarily returned to compliance and paid more than $10 billion in back taxes, interest, and penalties. At the same time, the IRS warned non-compliant taxpayers that its international compliance…