Another Swiss Asset and Financial Manager Reaches NPA with DOJ Tax (7/28/18)

DOJ Tax issued a press release, here, yesterday that Mirelis Holding, SA (Mirelis), a Swiss Asset and Financial Manager, had reached an NPA regarding its assistance for U.S. taxpayers.  Mirelis will pay an aggregate amount of $10.245 million broken down as follows:

Restitution:  $3.245 million
Disgorgement: $5 million
Other penalties: $2 million.

The press release is lengthy in giving many details.  Much of the typical pattern of Swiss Bank servicing of U.S. taxpayers hiding their income and assets.  The press release links the relevant documents, principally the NPA and Statement of Facts (identified as Download Mirelies (sic) NPA).

The following is an interesting disclosure:

Mirelis submitted a letter of intent to participate as a Category 2 bank in the Department’s Swiss Bank Program in December 2013.  Although it was ultimately determined that Mirelis was not eligible for the Swiss Bank Program due to its structure as both an asset management firm and a bank, Mirelis is required under today’s agreement to fully comply with the obligations imposed under the terms of that program.  Mirelis has fully cooperated with the Department of Justice in this investigation, including undertaking a separate and thorough review of the provision of independent portfolio and asset management services to U.S. taxpayer-clients with accounts maintained at third-party depository financial institutions and encouraging a significant number of its remaining non-compliant U.S. taxpayer-clients to participate, or provide proof of prior participation, in OVDP covering many of the U.S. Related Accounts maintained by Mirelis during the Applicable Period. 

Mirelis will be included on the IRS list of Foreign Financial Institutions or Facilitators, here,  (It was not on that list as of the posting of this blog entry.)  The press release says:

With today’s announcement of this non-prosecution agreement, noncompliant U.S. clients of Mirelis must now pay that 50 percent penalty to the IRS if they wish to enter the IRS Offshore Voluntary Disclosure Program.  The IRS recently announced that the Offshore Voluntary Disclosure Program will close on September 28, 2018.