The IRS has updated the list of banks that carry the higher penalty of 50% for undeclared accounts. A 50% offshore penalty applies if either a foreign financial institution at which the taxpayer has or had an account or a facilitator who helped the taxpayer establish or maintain an offshore arrangement has been publicly identified as being under investigation or as cooperating with a government investigation’ it says on the IRS website.
The IRS recommends to join the OVDP or other programs to avoid potential criminal liability or even civil penalties. The 50% penalty might seem high, but willful civil violations can draw penalties equal to the greater of $100k or 50% of the balance on the account for each violation -each year is a separate violation.
The Swiss institutions on the list
- UBS AG
- Credit Suisse AG, Credit Suisse Fides, and Clariden Leu Ltd.
- Wegelin & Co.
- Liechtensteinische Landesbank AG
- Zurcher Kantonalbank
- swisspartners Investment Network AG, swisspartners Wealth Management AG, swisspartners Insurance Company SPC Ltd., and swisspartners Versicherung AG
- Bank Leumi le-Israel B.M., The Bank Leumi le-Israel Trust Company Ltd, Bank Leumi (Luxembourg) S.A., Leumi Private Bank S.A., and Bank Leumi USA (effective 12/22/14)