Liechtenstein, an Alpine country of 36,000 people, has told American clients of the principality’s oldest bank that U.S. authorities have requested their account data as they widen a tax-evasion probe.
Accounts at Liechtensteinische Landesbank AG (LLB) that contained at least $500,000 at any time since the beginning of 2004 are covered by the information request, according to a May 30 letter sent to a client by the principality’s tax authority. Liechtenstein facilitated the so-called group request from the U.S. by amending a tax law in March.
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“The ruling to extend the period of applicability back to the tax year 2001 in the administrative assistance law with the U.S. is limited to 12 months from the date it comes into force,” said Sele. It “is closely linked to the ongoing U.S. offshore voluntary disclosure program."
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In the Liechtenstein group request, U.S. authorities are also targeting lawyers, accountants, financial advisers, asset managers and those responsible for professional “asset protection,” who “conspired with a U.S. taxpayer to commit U.S. crimes or provided assistance,” according to the letter.The requests are related to Liechtensteinische Landesbank ("LLB"), whose Swiss office is one of the target banks in the Swiss initiative.
Asher Rubinstein has a release discussing this developments. Here are some excerpts:
Liechtenstein was once the vanguard of offshore banking secrecy, and it was said that Swiss bankers kept their own money in Liechtenstein. * * * *
LLB account holders have an opportunity to challenge the release of banking information in Liechtenstein courts until June 15th. Owners of accounts at LLB have a very short window to apply for the OVDI. In light of the ongoing erosion of foreign banking secrecy, the inability of foreign governments to withstand U.S. pressure and the willingness of former tax havens to cooperate with the IRS, U.S. taxpayers with non-compliant accounts, in Liechtenstein and anywhere else, should meet with qualified tax counsel immediately to discuss tax compliance.See also Tax Blawg discussion here.