The IRS maintains a list of Foreign Financial Institutions or Facilitators, essentially a blacklist of institutions which have been determined to be complicit in evasion of U.S. taxes. While taxpayers who enter the IRS’ Offshore Voluntary Disclosure Program are normally subject to a penalty of 27.5%, those whose assets are on the ‘blacklist’ are instead subject to a 50% penalty on the highest aggregate balance of their accounts in the last eight years. To make matters worse, even one account in a ‘bad bank’ will taint the remainder of the assets and up the penalty to 50%.
The latest banks added to the blacklist are as follows:
- Bank J. Safra Sarasin SA(effective 12/23/15)
- Coutts & Co (effective 12/23/15)
- Gonet & Cie (effective 12/23/15);
- Banque Cantonal du Valais(effective 12/23/15);
- Banque Cantonale Vaudoise (effective 12/23/15);
- Bank Lombard Odier (effective 12/31/15);
- DZ Privatbank (Schweiz) AG (effective 12/31/15);
- Union Bancaire Privée, UBP SA(effective 1/6/16);
- Leodan Privatbank AG(effective 1/25/16)
The list is continuing to expand. Foreign Financial Institutions or Faciliators
