BSI Bank Lugano Signs DOJ Non-Prosecution Agreement

Yesterday, March 31, 2015, it was announced that BSI SA of Lugano signed the DOJ Non-Prosecution Agreement (NPA). Here is a summary:

  • DOJ Acting Deputy Attorney General Sally Yates – “We are using the information that we have learned from BSI and other Swiss banks in the program to pursue additional investigations into both the banks and individuals.”
  • Noted Requirements of the NPA for BSI
  • Provide detailed information on an account-by-account basis for account in which U.S. taxpayers have a direct or indirect interest
  • Provide detailed information as to other banks that transferred funds into secret accounts or that accepted fund when secret accounts were closed
  • BSI will pay a $211 million penalty
  • Tax Evasion Tactics Used by BSISham corporations and trusts to conceal identity of account holder
  • Numbered accounts
  • Credit or debit cards without names visible on the card itself
  • Help repatriating cash into the U.S. illegally by the use of refillable credit and debit cards with limits to avoid cash transaction reports (CTR)
  • Code words to gain access to funds“Can you download some tunes for us?”
  • “My gas tank is running empty”
  • Connected Jurisdictions
  • India, Luxembourg, Liechtenstein, Israel, Caribbean
  • Non-compliant U.S. account holders of BSI now must pay a 50% penalty if they join OVDP
  • BSI services 125,000 clients of which there are 3,000 to 4,000 accounts that are attributable to “known” U.S. taxpayers. The unknown amount will be determined by the cooperation between BSI and DOJ under the NPA over the next two to four years.

About Five Stone Tax Advisers

Five Stone Tax Advisers has years of experience negotiating directly with the IRS to get the best possible outcome for you. Our International Tax Advisory and Compliance unit has a team of tax attorneys, certified public accountants and enrolled agents that form a single sourced point of contact that will provide services for all the legal, compliance and financial reconstruction aspects of offshore account cases.

Five Stone Tax
by Five Stone Tax

Five Stone Tax is America’s trusted tax adviser, offering full-service tax solutions with the goal of making sure all of our clients pay the lowest amount of taxes legally possible. As the most effective tax representation company in America, our team consists of the best Property Tax Consultants, Tax Attorneys, Enrolled Agents, case managers, and administrators in the industry.

Subscribe to Our Blog!

Don’t miss out our filing tips & deadlines, global tax news and customer case studies

Give it a try—it only takes a click to unsubscribe.