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Keeping up with the changes, modifications, deletions, amplifications to the IRS Offshore Voluntary Disclosure Programs is definitely an effort. Just in the last 30 days, the IRS announcements were the following, in summary:

Since the 4th of August 2014, an individual will be imposed with an increase of 200% on the Offshore Penalty that was set at 27.5% to now 50%. As you may recall from my prior writings, the IRS has established a procedure for obtaining a pre-clearance letter for a fast-track completion of compliance and reduction of penalties. A new exception to this “fast track compliance” is when a bank in which you had or have an offshore account is now cooperating with the IRS or has been identified for IRS investigation.

Below is the current list of financial foreign institutions, (FFI) or “facilitators” who will act to terminate your pre-clearance letter and push your penalties up to 50% for having an offshore bank account. I definitely expect this list to grow rapidly as FATCA bring foreign banks into reporting Americans’ offshore bank accounts directly, via Internet submissions, which will be filtered by the IRS and promptly acted upon. For the moment, here are the named IRS FFIs that are cooperating with the IRS or have been investigated by the IRS:

2. Credit Suisse AG
3. Credit Suisse Fides
4. Clariden Leu Ltd.
5. Wegelin & Co.
6. Liechtensteinische Landesbank AG
7. Zürcher Kantonalbank;
8. Swiss Partners Investment Network AG
9. Swiss Partners Wealth Management AG
10. Swiss Partners Insurance Company SPC Ltd.
11. Swiss Partners Versicherung AG
12. CIBC First Caribbean International Bank Limited, its predecessors, subsidiaries, and affiliates;
13. Stanford International Bank, Ltd.
14. Stanford Group Company
15. Stanford Trust Company, Ltd.
16. The Hong Kong and Shanghai Banking Corporation Limited in India (HSBC India)
17. The Bank of N.T. Butterfield & Son Limited (also known as Butterfield Bank and Bank of Butterfield), its predecessors, subsidiaries, and affiliates.

Michael Nelson

Michael has great depth of experiences and skills that evolved from over 35 years of representing international businesses, executives, expatriates and multi-national families. From these years of successful legal representations of CEOs of Fortune 500 Companies to family clients with needs from complex estate planning to international trusts and private foundations. He is committed to his clients, always finding better alternatives or options for his clients. Dedication to the client is synonymous with his name.