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As the voluntary disclosure program for Swiss Banks proceeds at a rapid pace, the question number one among U.S. international tax attorneys is what will happen to the undisclosed bank accounts in Switzerland. In order to understand the impact of the US Department of Justice (“DOJ”) the Program for Non-Prosecution Agreements or Non-Target Letters for […]
On November 14, 2013, the U.S. Department of the Treasury announced that the United States has signed an intergovernmental agreement (IGA) with France to implement the Foreign Account Tax Compliance Act (FATCA). Enacted in 2010, France FATCA IGA aims to curtail offshore tax evasion by facilitating the exchange of tax information. With France FATCA IGA, […]
FATCA Switzerland: FATCA Legislation Approved On September 23, 2013, Swiss Senate voted to approve the implementation of Foreign Account Tax Compliance Act (FATCA). This event came barely a few weeks after the Swiss House of Representative approved the same legislation. At this point, Swiss Banks have a clear way to cooperate with the IRS and […]
As offshore voluntary disclosure lawyers know very well, Switzerland continues to be the center of the unprecedented IRS and US Department of Justice enforcement of U.S. international tax laws, including FATCA. In a recent article, I described a new initiative, The Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks (the “Program”), which is […]
While looking for a San Francisco international tax lawyer, one of the important issues that clients face is whether it is better to retain an international tax attorney in San Francisco or in Minneapolis if you live in San Francisco? If you were to search “San Francisco international tax lawyer”, Sherayzen Law Office, Ltd. (which […]