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Credit Suisse

Recently, the Swiss Finance Minister gave the United States Department of Justice (DOJ) and the Internal Revenue Service (IRS) millions of encoded emails between Swiss bank client advisors and their U.S. clients. When a deal is made between the Swiss and the U.S., the key to decoding these documents will be given to the IRS. Credit Suisse and Clariden Leu are among the Swiss banks involved, for U.S. taxpayers with undisclosed offshore accounts, now is the time to come forward.

The IRS has announced 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 is based on the highest total account balance over an 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.


Participants who successfully complete the 2012 IRS Offshore Voluntary Disclosure Program can avoid criminal prosecution, and severe civil penalties.

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

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