Friday, December 26, 2014

IRS Updates List of Foreign Financial Institutions or Faciliators with Bank Leumi and Sovereign Management & Legal Ltd. (12/26/14)

The IRS has updated its list of Foreign Financial Institutions or Facilitators, here.  One function of this list is to identify banks that the insided OVDP penalty rate increases to 50%. (See FAQ 7.2, here.)

The new list is as follows (with the additions in bold-face):

  • UBS AG
  • Credit Suisse AG, Credit Suisse Fides, and Clariden Leu Ltd.
  • Wegelin & Co.
  • Liechtensteinische Landesbank AG
  • Zurcher Kantonalbank
  • swisspartners Investment Network AG, swisspartners Wealth Management AG, swisspartners Insurance Company SPC Ltd., and swisspartners Versicherung AG
  • CIBC FirstCaribbean International Bank Limited, its predecessors, subsidiaries, and affiliates
  • Stanford International Bank, Ltd., Stanford Group Company, and Stanford Trust Company, Ltd.
  • The Hong Kong and Shanghai Banking Corporation Limited in India (HSBC India)
  • The Bank of N.T. Butterfield & Son Limited (also known as Butterfield Bank and Bank of Butterfield), its predecessors, subsidiaries, and affiliates
  • Sovereign Management & Legal, Ltd., its predecessors, subsidiaries, and affiliates
  • Bank Leumi le-Israel B.M., The Bank Leumi le-Israel Trust Company Ltd, Bank Leumi (Luxembourg) S.A., Leumi Private Bank S.A., and Bank Leumi USA

For the Federal Tax Crimes Blogs postings on the newly added institutions, see:

  • Bank Leumi Admits Tax Wrongdoing, Agrees to Deferred Prosecution agreement, and Agrees to $400 Million Payments (Federal Tax Crimes Blog 12/22/14), here.
  • New Direction for John Doe Summonses to An Enabler's Service Providers Subject to Summons Power (Federal Tax Crimes Blog 12/19/14), here.

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