Both house of the Swiss parliament have finally approved a tax treaty with the United States. The change in Swiss law means that Switzerland’s biggest bank, United Bank of Switzerland (UBS) will hand over to the United States Department of Justice the details of nearly 4,500 of their U.S. clients. At last minute, one political party changed its mind about calling for a referendum on the issue which would have caused a delay in the implementation of the treaty.
This means that the 4,500 UBS clients whose names will be disclosed to the US Department of Justice will likely face criminal prosecution and very large civil penalties. Our firm has been preparing our clients for the past year of just such an eventuality. Many of our clients have entered into the Global Voluntary Disclosure program offered by the Internal Revenue Service (IRS). By entering into the Global Voluntary Disclosure program, our clients will likely avoid any criminal penalties associated with holding an undisclosed foreign bank account. Their exposure to civil penalties has also been significantly reduced.
If you have an undisclosed foreign bank account and have not entered into the IRS’ Global Voluntary Disclosure program, you should consider the benefits of entering into the program. By entering into the Global Voluntary Disclosure program you could avoid criminal prosecution and reduce your exposure to the crippling civil penalties.