“The IRS’s Better Offshore Amnesty Program has sparked new interest in cleaning up offshore accounts. The timing is good, since over 100 Swiss banks are about to provide data to the IRS. More globally, FATCA disclosures are right around the corner. Many foreign banks are rooting out Americans with increasing vigilance.
Although many of the changes in the IRS deal are liberalizing, some changes to the Offshore Voluntary Disclosure Program are not. For some, the penalty goes from 27.5% To 50%. But for who? The IRS has released a list of the 10 firms currently under investigation whose clients could be subject to this new 50% penalty.”
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