On Thursday, June 19, 2014, we posted "OVDP Penalty Increased To 50%!"where we discussed that the new revisions to the US offshore voluntary disclosure initiative, which we posted on 6/18/14 "IRS Makes Changes to Offshore Programs; Revisions Ease Burden and Help More Taxpayers Come into Compliance", now provides for and increased 50% FBAR Penalties for 'Willful' Non-Disclosers.
This group includes those individuals
who have offshore bank accounts with a foreign financial institution
which has been publicly identified as being under investigation, or is
cooperating with a government investigation. IRS has published a list of those foreign financial institutions or facilitators.
The complete list is as follows:
The same goes for taxpayers who worked with a "facilitator" who helped the taxpayer establish or maintain an offshore arrangement if the facilitator has been publicly identified as being under investigation or as cooperating with a government investigation.
If they do not enter the OVDP by that date then they will still be eligible to enter the OVDP, but they will be subject to a 50% offshore penalty, rather than the existing 27.5 percent penalty.
Of course if the IRS already has a particular taxpayer's name, then that person will not be eligible to enter the OVDP, and could be subject to multiple FBAR penalties.
The complete list is as follows:
- UBS AG
- Credit Suisse AG, Credit Suisse Fides, and Clariden Leu Ltd.
- Wegelin & Co.
- Liechtensteinische Landesbank AG
- Zurcher Kantonalbank
- Swisspartners
- CIBC FirstCaribbean International Bank Limited, its predecessors, subsidiaries, and affiliates
- Stanford International Bank, Ltd., Stanford Group Company, and Stanford Trust Company, Ltd.
- HSBC India
- The Bank of N.T. Butterfield & Son Limited (also known as Butterfield Bank and Bank of Butterfield).
The same goes for taxpayers who worked with a "facilitator" who helped the taxpayer establish or maintain an offshore arrangement if the facilitator has been publicly identified as being under investigation or as cooperating with a government investigation.
Those individuals have until August 3, 2014 to enter the OVDP.
If they do not enter the OVDP by that date then they will still be eligible to enter the OVDP, but they will be subject to a 50% offshore penalty, rather than the existing 27.5 percent penalty.
Of course if the IRS already has a particular taxpayer's name, then that person will not be eligible to enter the OVDP, and could be subject to multiple FBAR penalties.
Just 3 Days Before OVDP Penalty Increase To 50%!
Taxpayers Must Act Quickly!
Contact the Tax Lawyers at
Marini & Associates, P.A.
for a FREE Tax Consultation Contact US at
or Toll Free at 888-8TaxAid (
(888) 882-9243)
(888) 882-9243)
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