Neue Zuercher Bank

The United States Department of Justice (DOJ) and the Internal Revenue Service (IRS) are actively investigating the Swiss bank Neue Zuercher Bank (NZB) following the 2009 indictment of a NZB bank executive on charges he assisted U.S. taxpayers in committing tax fraud.

Swiss authorities, through negotiations with U.S. officials, have turned over thousands of pages of encoded data containing information to identify U.S. taxpayers with offshore accounts at Neue Zeurcher Bank and other Swiss banks. As soon as the Swiss and the U.S. reach agreement, the Swiss authorities will decode the data and the DOJ and the IRS will begin investigating U.S. taxpayers with undisclosed offshore accounts.

The IRS has introduced its 2012 Offshore Voluntary Disclosure Program for taxpayers with undisclosed offshore accounts.

Thorn Law Group currently represents United States taxpayers making voluntary disclosures of their offshore accounts.

Basic terms of the 2012 IRS Amnesty program are:

1. The 27.5 percent penalty of the undisclosed offshore accounts that is based on the highest total account balance over the past eight-year period.
2. Taxpayers must pay back taxes and interest on any unreported income for up to eight years as well as accuracy related and/or delinquency penalties.
3. Taxpayers must file all original and amended tax returns and include payments for taxes, interest and accuracy related penalties.
4. Participants who successfully complete the 2012 IRS Offshore Voluntary

Disclosure Program can avoid criminal prosecution, and substantial civil penalties.

For a consultation, contact Kevin E. Thorn, Managing Partner, at ket@thornlawgroup.com or (617) 692-2989.

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