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US/Swiss accord on tax evasion: ‘FATCA on steroids’

Swiss banks got something of a loaded holiday gift on Thursday 28 August as the Justice Department offered a non-prosecution agreement to banks that deliver voluntary disclosure of US account holders.
Jim Mastracchio chair of the tax controversy practice at law firm BakerHostetler praised the settlement on several grounds. ‘This agreement is ingenious ’ he said. ‘It provides all financial institutions in Switzerland the ability to make a voluntary disclosure with US authorities and receive a non-prosecution agreement – just like the offshore voluntary disclosure offer to offending US citizens. The bonus for the government is either the collection of civil monetary penalties for foreign institutions that can be as high as 50% of the US taxpayer’s account balance or the taxpayer can make a voluntary disclosure and pay a penalty of 27.5%. Both options represent a huge revenue...

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