Offshore Voluntary Disclosures - Switzerland

U.S. OFFSHORE VOLUNTARY DISCLOSURES

Overview of the 2012 U.S. IRS OVDP and Switzerland Update

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Gray International (“Gray”) is an international network of public accounting and consulting Iirms based in the U.S., Hong Kong, China and Europe. Gray was started over 10 years ago in the U.S. (via its predecessor) and took the form of Gray International in 2013 as the result of the networking of multiple independent practices and professionals. Gray provides international accounting and compliance solutions in the U.S., Americas, Asia and Europe. Gray focuses on U.S. accounting, tax, and governmental compliance for multinational companies,

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GRAY SWITZERLAND Gray has extensive experience working in Switzerland. The Firm has represented both Swiss companies and individuals, as well as U.S. taxpayers who have sough relief under the U.S. Offshore Voluntary Disclosure Program (OVDP). The Firm launched its (Swiss Bank) Independent Examiner services in response to the release of the Program For Non-‐Prosecution Agreements or Non-‐Target Letters for Swiss Banks, by and between the U.S. Department of Justice and Swiss Federal Department of Finance, on August 29, 2013. The Firm has a depth of relationships in Switzerland, and has extensive experience operating under both Swiss law and in compliance with U.S. laws and regulations (both tax and securities). The Firm is committed to Switzerland, and as a result Switzerland is one of our key markets. The Firm focuses on the following key practice areas in Switzerland:


OFFSHORE VOLUNTARY DISCLOSURES PFIC REPORTING/COMPLIANCE

U.S. TAX OPINIONS

FATCA IMPLEMENTATIONS (SWISS BANK) INDEPENDENT EXAMINER


OVDP: SWITZERLAND UPDATE

AS OF NOVEMBER 5, 2013


2013 SWITZERLAND UPDATES The last Iive years has seen a signiIicant focus by the U.S. Department of Justice (“DOJ”) on Swiss Bank U.S. Cross-‐border

business for U.S. account holders who have hid assets and income from the IRS in undeclared accounts. Enforcement efforts from the DOJ have led to the following major events in Switzerland (and worldwide):

•  Signing of the “Program for Non-‐Prosecution Agreements or Non-‐Target Letters for Swiss Banks” (the

“Program”) as announced jointly by the United States Department of Justice (the “DOJ”) and the Swiss Federal Department of Finance on August 29, 2013 – this is essentially an Offshore Voluntary Disclosure for Swiss Banks (program summary in the following slides).

•  In February 2009, UBS entered into a deferred prosecution agreement (“DPA”) and admitted guilt on charges of conspiring to defraud the United States by impeding the IRS. UBS paid $780 million in Iines, penalties and interest related to the DPA. UBS provided to the U.S. information about thousands of recalcitrant U.S. Taxpayers.

•  In January of 2013, the U.S. Attorney’s OfIice in the Southern District of New York secured the guilty plea of Wegelin Bank (the oldest private bank in Switzerland) which was the Iirst foreign bank to plead guilty to felony tax charges. Wegelin bank was shut down as a result of this action.

•  Worldwide: From 2008 through 2013, the DOJ Tax Division has charged over 30 banking professional and 60 account holders, thus far resulting in Iive convictions after trial and 55 guilty please, including 2 trial convictions and 6 guilty pleas in the Iirst four months of 2013 alone.

•  Worldwide: As of December 2012 the combined IRS Offshore Voluntary Disclosure Program (“OVDP”) submissions resulted in more than 39,000 disclosures by taxpayers, of these taxpayers almost half had accounts in Switzerland (as indicated in the U.S. GAO Report).

•  Popular estimates are that between 4,000 – 5,000 new OVDP submissions will result from the DOJ Program. •  There are currently 14 Swiss Banks under active investigation by the DOJ.


THE 2013 DOJ NPA/NTL PROGRAM

The “Program for Non-‐Prosecution Agreements or Non-‐Target Letters for Swiss Banks” as announced jointly by the United States Department of Justice (the “DOJ”) and the Swiss Federal Department of Finance on August 29, 2013 ( “the Program”) is open to every Swiss Bank that is not currently under investigation by the DOJ (further deIined as Category 1 Banks). The Program provides a mechanism for banks to resolve past U.S. cross-‐border regulatory exposure, deIine their potential exposure, and mitigate penalties (if their U.S. account holders duly disclose the existence of the account(s) under an Offshore Voluntary Disclosure after the bank has notiIied the client of such program). Compliance with the Program should result in the avoidance of prosecution by the DOJ. The key features of the program are as follows:

•  Category 1 Banks (e.g. the 14 banks that are already under investigation by the DOJ) are not

eligible to participate in the program.

•  Category 2 Banks (e.g. banks that have reason to believe that they may have committed U.S. tax-‐related offenses) will pay a penalty and may request a Non-‐Prosecution Agreement (“NPA”) from the DOJ.

•  Category 3 and 4 Banks will be able to prove compliance with U.S. laws (i.e. prove their

innocence) and will obtain a Non-‐Target Letter (“NTL”) from the DOJ and will not pay penalties.



DOJ NPA - PENALTY STRUCTURE

Upon execution of an NPA (for Category 2 Banks) , the Swiss Bank will agree to pay as a penalty:

•  For U.S. Related Accounts that existed on August 1, 2007, an amount equal to 20% of the maximum aggregate dollar value of all such accounts during the Applicable Period;

•  for U.S. Related Accounts that were opened between August 1, 2008, and February 28, 2009, an amount equal to 30% of the maximum aggregate dollar value of all such accounts; and

•  for U.S. Related Accounts that were opened after February 28, 2009, an amount equal to 50% of the maximum aggregate value of all such accounts.

•  Penalty Mitigation Provision: The determination of the maximum dollar value of the aggregated U.S. Related Accounts may be reduced by the dollar value of each account as to which the Swiss bank demonstrates, to the satisfaction of the DOJ, was not an undeclared account, was disclosed by the Swiss Bank to the U.S. IRS, or was disclosed to the U.S. IRS through an announced Offshore Voluntary Disclosure Program or Initiative following notiIication by the Swiss Bank of such a program or initiative and prior to the execution of the NPA.



THE 2013 DOJ NPA/NTL PROGRAM: OVDP IMPACT

It is estimated that the 2013 DOJ Program will see wide adoption by Swiss banks. The (estimated) success of the Program and the implementation of FATCA means that the DOJ and IRS will have massive amounts of data about U.S. recalcitrant taxpayers in the very near term. Because of the reasons above, and the fact that the participating Swiss Banks have an incentive (penalty mitigation) to recommend their U.S. account holders to come forward under the OVDP (and the U.S. taxpayers will be made aware that their data will be shared with the DOJ), it is likely that the volume of Taxpayers seeking the protections of the OVDP will increase dramatically in 2013 and 2014.



THE 2012 U.S. IRS OFFSHORE VOLUNTARY DISCLOSURE

PROGRAM

A BRIEF OVERVIEW


THE 2012 PROGRAM

The 2012 Offshore Voluntary Disclosure Program (“OVDP”) is a limited federal income tax amnesty program for U.S. taxpayers who have used undisclosed foreign accounts and undisclosed foreign entities to avoid or evade tax. Once a taxpayer successfully completes the program, the taxpayer escapes certain severe civil and criminal penalties. Without the program potential civil penalties penalties can far exceed the balance of the foreign assets or accounts, and the criminal penalties can result in federal prosecution and jail time. The taxpayer completes the program by fully and truthfully reporting the offshore assets and income, Iiling amended returns, foreign account and asset declarations (and other disclosures) and paying the following penalties (note: certain circumstances may qualify a taxpayer for reduced penalties): The OVDP Penalty based on 27.5% of the highest combined value of the taxpayer’s previously unreported foreign Iinancial accounts and certain other assets (in limited cases this may be reduced to 15% or 5%):

•  Pay all previously unpaid taxes associated with the undisclosed Iinancial accounts and assets

•  Pay IRC § 6662(a) accuracy-‐related penalty of 20% of the amount of the unpaid tax

•  Pay IRC § 6651(a)(1) failure to Iile penalties (if applicable)

•  Pay IRC § 6651(a)(2) failure to pay penalties (if applicable)

•  Pay interest on unpaid taxes


WHY MAKE A VOLUNTARY DISCLOSURE?

Taxpayers with undisclosed foreign accounts or entities should (in most cases) make a voluntary disclosure because it enables them to become compliant, avoid substantial civil penalties and generally eliminate the risk of criminal prosecution. Making a voluntary disclosure also provides the opportunity to calculate with a reasonable degree of certainty, the total cost of resolving all offshore tax issues. Taxpayers who do not submit a voluntary disclosure run the risk of detection by the IRS and the imposition of substantial penalties, including the fraud penalty and information return penalties which may exceed the value of the account, and an increased risk of criminal prosecution. The Internal Revenue Services (“IRS” and “Service”) and U.S. Department of Justice (“DOJ”) have ever increasing access to foreign account information via treaties and legal action, that and the implementation of the Foreign Account Tax Compliance Act (“FATCA”) and Foreign Financial Asset Reporting (new IRC § 603D) will mean more and more undisclosed accounts will be subject to discovery and reporting. Recent DOJ wins in countries like Switzerland, Lichtenstein and other jurisdictions known for bank secrecy (that was legally protected) means that more and more foreign account information is being actively disclosed and made available to U.S. authorities.


POTENTIAL CRIMINAL PENALTIES

Taxpayers with undisclosed foreign accounts or entities and income, can face prosecution for the following criminal matters if the IRS examines them: •  Tax evasion (26 U.S.C. § 7201). This can carry a prison term of up to Iive

years and a Iine of up to $250,000. •  Filing a false return (26 U.S.C. § 7206(1)). This can carry a prison term of up

to three years and a Iine of up to $250,000.

•  Failure to Iile an income tax return (26 U.S.C. § 7203). This can carry a prison term of up to one year and a Iine of $100,000.

•  Criminal penalties for FBAR violations (31 U.S.C. § 5322). This can carry a prison term of up to ten years and criminal penalties of up to $500,000.


POTENTIAL CIVIL PENALTIES Taxpayers with undisclosed foreign accounts or entities and income, can face the following civil penalties if discovered: •  Penalty for failure to Iile the Form TD F 90-‐22.1 (Report of Foreign Bank and Financial Accounts), as high as the

GREATER of $100,000 or 50% of the value of the total balance of the account – PER VIOLATION (31 U.S.C. § 5321(a)(5)) [note: non-‐willful violations that the IRS determines were not due to reasonable cause are subject to a $10,000 penalty per violation].

•  Beginning with the 2011 tax year, a penalty for failing to Iile form 8938 reporting the Taxpayer’s interest in

certain foreign Iinancial assets, including Iinancial accounts (I.R.C. § 603D) – $10,000 PER Violation and $10,000 added per month for each month the failure continues beginning 90 days after the taxpayer is notiIied of the delinquency, up to a maximum of $50,000 per return.

•  A penalty for failing to Iile form 3520, Annual Return to Report Transaction with Foreign Trusts and Receipt of Certain Foreign Gifts – the GREATER of $10,000 or 35 percent of the gross reportable amount, and in the case of gifts, an additional penalty of 5% of the gift per month up to a maximum penalty of 25% of the Gifts.

•  A penalty for failing to Iile Form 3520-‐A, Information Return of Foreign Trust With a U.S. Owner (I.R.C. § 6048(b) – the penalty for each one of these returns is the GREATER of $10,000 or 5% of the gross value of the trust assets determined to be owned by a United States person.

•  A penalty for failing to Iile Form 5471, Information Return of U.S. Returns with Respect to Certain Foreign Corporations I.R.C. §§ 6035, 6038 and 6046) – $10,000 per violation and $10,000 each month after 90 days that the taxpayer is notiIied of the delinquency, up to a maximum of $50,000 per return.

•  A penalty for failing to Iile Form 926, Return by a U.S. Transferor of Property to a Foreign Corporation (I.R.C. § 6038B) – 10% of the value of the property transferred up to a maximum of $100,000 per return, with no limit if the failure to report the transfer was intentional.


POTENTIAL CIVIL PENALTIES (cont.) •  A penalty for failing to Iile Form 8865, Return of U.S. Persons With Respect to Certain

Foreign Partnerships. (I.R.C. §§ 6038, 603B and 6046A) -‐ $10,000 penalty for failure to Iile each return, with an additional penalty of $10,000 added per day 90 days after the taxpayer is notiIied of the delinquency, up to a maximum of $50,000 per return and 10% of the value of any transferred property that is not reported subject to a $100,000 limit.

•  Fraud penalties imposed under IRC §§ 6651(f) or 6663. Where an underpayment of tax, or a failure to Iile a tax return, is due to fraud, the taxpayer is liable for penalties that, although calculated different, essentially amount to 75% of the unpaid tax.

•  A penalty for failing to pay the amount of the tax shown on the return under IRC § 6651(a)(2) of 5% of the balance due plus and additional 5% for each month of a fraction thereof during which the failure continues may be imposed, not to exceed 25%.

•  A penalty for failing the pay the amount of tax shown on the return under IRC § 6651(a)(2) of .5% of the amount of the tax shown on the return, plus an additional .5% for each additional month or fraction thereof that the amount remains unpaid, not exceeding 25%.

•  An accuracy-‐related penalty on underpayments imposed under IRC §§ 6662, depending on which component of the accuracy penalty is applicable the penalty can be 20 to 40% of the tax.


ELIGIBILITY Taxpayers (both individuals and entities) who have undisclosed offshore accounts or assets and meet the requirements of IRM 9.5.11.9 are eligible to apply for IRS Criminal Investigation’s OVDP. In general terms, Taxpayers with the following characteristics are NOT eligible:

•  Taxpayers whom the IRS has initiated a civil examination, regardless of whether it relates to undisclosed foreign accounts or undisclosed foreign entitles.

•  Taxpayers whose accounts or assets were funded through illegal sources. •  Taxpayers that the IRS or DOJ have obtained (under a John Doe Summons, treaty request, or

similar action) evidence of the Taxpayer’s non-‐compliance (note: a Taxpayer concerned that a party subject to a John Doe summons, treaty request or similar action, will provide information about him/her to the IRS should apply to make a voluntary disclosure as soon as possible.

•  A Taxpayer appeals a foreign tax administrator’s decision authorizing the providing of account

information to the Service and fails to serve the notice as required under existing law (see 18 U.S.C. 3506).

•  The IRS may announce that certain taxpayer groups that have or had accounts at speciIic

Iinancial institutions will be ineligible due to U.S. government actions in connection with the speciIic Iinancial institution.


WHAT IS REQUIRED? For the 8 year disclosure period (note: speciIic rules apply to instances whereby a Taxpayer was compliant in some years during the disclosure period) the Taxpayer must do the following (note: among other disclosures and submissions):

•  Disclose the previously unreported foreign assets and income.

•  Disclose persons who helped hide the foreign assets and income, such as advisors, bankers, attorneys, accountants, business associates and family members.

•  File amended federal income tax returns.

•  Pay previously unpaid taxes and penalties as detailed earlier.

•  File amended, or corrected information returns and disclosures (such as the Treasury Department’s Report of Foreign Financial Accounts TD F 90-‐22.1, IRS form 8938 (statement of speciIied foreign Iinancial assets), IRS form 8621 (for investments in passive foreign investment companies), IRS form 926 (for transfers of cash or other property to foreign corporations), IRS form 8865 (for investments in foreign controlled partnership), and IRS form 5471.


WHAT IS THE PROCESS? 1.  Pre-‐clearance: Information about the Taxpayer is provided to the IRS Criminal

Investigation Division (“IRS CI”) along with a request for pre-‐clearance to make an application under the program. The IRS then notiIies that Taxpayer if they are preliminarily eligible (this is NOT a binding position of the IRS and may be revoked at any time). The Taxpayer then has 45 days from the receipt of the pre-‐clearance letter to submit the information required under Step 2.

2.  Criminal Review: The Taxpayer then submits an offshore disclosure letter and

attachment (for each group of offshore accounts or assets) to the IRS CI which provides details about the location and range of value of the account, the individuals and entities involved in the custody, management and promotion of the account as well as the source of funds for the account (in particular interest to the IRS is whether these were obtained from lawful means). If preliminarily accepted IRS CI will then notify the taxpayer to submit the required information and payment (or proposal for installment agreement) required under Step 3.

3.  Civil Review: Substantial additional information is then provided to a civil

examiner. This information includes amount other things, payment of the penalties and interest associated with the application, amended returns for the disclosure period, consents to extend time to assess tax and penalties, extensive foreign account records, amended or original information returns and treasury department foreign account and asset disclosures.


MAJOR CONSIDERATIONS A decision to participate in the process should be made carefully and with the assistance of qualiIied professional advice. Some (but not all) major considerations for a Taxpayer considering the OVDP program are listed below:

•  Penalties are high and can equate 50% or more of the current account value (note: in some cases can equal or exceed the account value due to Iluctuations in asset value, market losses in the account, bad investments, foreign currency exchange rates and other variables).

•  The compliance costs are high. Program submission requires signiIicant work to prepare

amended returns, corrected or original disclosures, calculation of penalties and interest, and in some cases forensic work to reconcile the foreign accounts.

•  The Taxpayer will be required to identify persons who facilitated the offshore account and this can be friends, family and business partners.

•  The process may take a long time, it is not unusual for an OVDP application to take 1 or 2 years.

•  Applying does not guarantee approval. While most timely Iiled and truthful applications are accepted (the taxpayer inspector general indicates that the approval rate is more than 90%) it is not guaranteed that they will be. If the application is rejected then the Taxpayer would not have any protection against an assertion of civil or criminal penalties by the IRS.

•  It may be difIicult to obtain the required documents, and it may require legal action in the

domicile of the account or asset.


A NOTE ABOUT QUIET DISCLOSURES

The IRS is aware that some Taxpayers made so-‐called “quiet” disclosures by Iiling amended returns and reporting the income from their foreign assets and accounts, paying the interest and penalties, but did not make a formal OVDP application. These Taxpayers are still eligible (given that they also Iit the general eligibility guidelines) to take advantage of the OVDP by submitting an application.

The IRS strongly encourages these Taxpayers to come forward under the OVDP to make timely, accurate and complete disclosures. Those Taxpayers making “quiet” disclosures should be aware of the risk of being examined and potentially criminally prosecuted for all applicable years.


GRAY CAN HELP

If you are considering making a voluntary disclosure Gray can help. Our experienced tax professionals are focused on helping Taxpayers through the Offshore Voluntary Disclosure Process. If you are concerned that you are at risk of IRS action related to your undisclosed accounts contact us today, if not disclosed and discovered, the penalties and potential criminal liability is signiIicant. Since the IRS is obtaining more and more information about foreign account the time to take the decision to enter the OVDP is now.


FULL PROGRAM REPRESENTATION

PREPARATION OF ALL RETURNS AND FILINGS

FORENSIC ACCOUNTING/RECORD RECONSTRUCTION

CALCULATION OF PENALTIES AND INTEREST

PREPARATION OF SUBMISSION FILING


CONTACT US

Website www.grayintl.com

E-mail [email protected]

Addresses U.S. International OfIice Attn: Jeremy Stobie, CPA, CFE 10900 NE 8th Street Suite 1000 Bellevue, WA 98004

Phone + 001 425.999.3685 xt 10

Gray welcomes your questions, comments and inquiries and would like the opportunity to serve you.


Offshore Voluntary Disclosures - Switzerland

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