Information – Useful Links

U.S. Department of Justice
Department of Justice Tax Division
The U.S. Tax Division’s mission is to enforce the nation’s tax laws fully, fairly, and consistently, through both criminal and civil litigation, in order to promote voluntary compliance with the tax laws, maintain public confidence in the integrity of the tax system, and promote the sound development of the law.

Internal Revenue Service - IRS - Logo
Internal Revenue Service IRS
The U.S. Internal Revenue Service is the nation’s tax collection agency and administers the Internal Revenue Code enacted by Congress.

Federal Tax Crimes - Blog - Jack Townsend
Federal Tax Crimes – Blog Jack Townsend
Jack Townsend’s blog offers among other topics interesting insights for the readers of the US Tax Program for Swiss Banks

FATCA - Foreign Account Tax Compliance Act
FATCA Foreign Account Tax Compliance Act
FATCA agreement
US Tax Authority IRS
US Department of the Treasury

DTT - Double Tax Treaty
DTT Double Tax Treaty - 1996
According to the US withholding tax regulations a non-resident alien may claim Treaty relief if this person is entitled to Treaty benefits.

Most U.S. taxpayers who enter the IRS Offshore Voluntary Disclosure Program to resolve undeclared offshore accounts will pay a penalty equal to 27.5 percent of the high value of the accounts.  On Aug. 4, 2014, the IRS increased the penalty to 50 percent if, at the time the taxpayer initiated their disclosure, either a foreign financial institution at which the taxpayer had an account or a facilitator who helped the taxpayer establish or maintain an offshore arrangement had been publicly identified as being under investigation, the recipient of a John Doe summons or cooperating with a government investigation, including the execution of a deferred prosecution agreement or non-prosecution agreement.

Noncompliant U.S. accountholders at Banks listed under Foreign Financial Institutions or Facilitators must now pay that 50 percent penalty to the IRS if they wish to enter the IRS Offshore Voluntary Disclosure Program (OVDP).


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