On June 5, 2014, the Tax Division of the DoJ further commented on the Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks. The main take out is the deadline extension for Category 2 Banks.
As the deadline for the Category 2 Banks is being extended, they now have until July 31 to hand over the requested information . The US Department of Justice extended the original June 30 deadline to July 31 because a number of banks seemed to be having trouble verifying whether an account was undeclared or disclosed in a timely manner to the US Internal Revenue Service.
Further comments refer to the following areas:
– Authorization of formal criminal investigation (Program I.A and V.A)
– Coverage of the non-prosecution agreement (Program II.C and II.J)
– Maximum aggregate dollar value and penalty mitigation (Program II.H.)
– Identities of third parties involved in structuring, operating, and supervising cross-border business (Program II.D.1)
– Identities of relationship manager, client advisor, asset manager, etc. (Program II.D.2.v)
– Information concerning transfers of funds into and out of the account (Program II.D.2.vi)
– Receipt of Independent Examiner verification (Program II.B and II.D.3)
– Assistance with treaty requests (Program II.D.4)
– Extension of deadlines relating to mitigation of penalty amounts (Program II.H)
– Publicity of non-prosecution agreements
– Categories 3 and 4 Deadlines (Program III.B and IV.B)
It mainly impacts the 106 banks that plan to take part in the US Program under Category 2.
Many media reported the news.