The Swiss government is thinking about the proposed settlement in the UBS litigation.  (The settlement would have UBS disclose some names, but not the names of all of its 52,000-ish U.S. customers.  Convenient fig leaf for UBS and IRS.) Reuters reports on Swiss cabinet meetings on this point.  From the article, we can see a [...]

Yesterday I posted about the IRS strategy was in the FBAR amnesty process–a quest to identify other Swiss banks, then go after them hammer and tongs (Caution:  sound file) in order to squeeze names of U.S. taxpayers out of them or scare bank customers into voluntary disclosure. Here’s evidence that the hunting strategy is indeed [...]

One of the recurring questions I get is whether going through the amnesty process will cause the IRS to declare open season on all of the prior year tax returns.  Will you be audited for all of your completely unrelated income and deductions if you come forward and declare your previously-hidden offshore bank account? No [...]

It’s a giant data sweep. With a defined aim. Unfortunately, the scheme may be turning out badly, if my experience is typical. Here’s the plan: Announce the amnesty. Yell “Scary Monsters!” as loudly and frequently as you can, and get as much press as you can. Taxpayers apply for the amnesty so they can sleep [...]

Up to now the FBAR amnesty processing dance has been: Step 1. Go to your local IRS Criminal Investigations office. Get cleared there. Step 2. Get your file sent to the IRS Philadelphia unit, where most things international seem to happen. This is where your taxes, penalties, and interest would be calculated. I know it [...]