If you have moved your accounts from Switzerland to another country because of an impending investigation, or you’re considering doing so, think twice about it.

The Department of Justice Tax Division released commentary and guidance in regards to the Program for Non-Prosecution Agreements (NPA) or Non-Target Letters (NTL) for Swiss Banks.
The commentary reiterated several deadlines and points that are worth mentioning.

The Tax Division of the Department of Justice has open investigations into numerous offshore banks located in Switzerland. These investigations are part of the Program for Swiss Banks (PFSB) as detailed in a joint statement press release by the United States and Switzerland.

It is estimated that hundreds of thousands of American citizens and holders of permanent residency status in the United States live in Israel. While U.S. citizens are required to file reports with the Internal Revenue Service about their incomes and holdings in foreign banks even if they live abroad, it is thought that large numbers of people who have dual American-Israeli citizenship and live in Israel have failed to do so.

Per the Intergovernmental Agreement (IGA) between Canada and the United States, on July 1st, 2014, information sharing between both countries will commence.

The eligibility requirements for expanded Streamline Filing were published on June 18th, 2014. There are two ways for a taxpayer to engage in Streamline Filing.

Ten Swiss banks have requested to be removed from consideration for non-prosecution agreements offered by the Department of Justice.

If you have undisclosed accounts, this filing process becomes even more complicated. Thankfully the IRS has programs, including Offshore Voluntary Disclosure Program (OVDP) to help reach compliance.