How will USCs and LPRs living overseas be affected? Credit Suisse is reportedly in talks to pay well over $ 1 billion to resolve tax transgressions with the U.S. Department of Justice

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UBS paid US$780M to resolve its issues with the US DOJ and IRS in 2009.  It’s deferred prosecution agreement seemed harsh to many at the time.  However, if recent news reports are correct, Credit Suisse will be paying well over $1 Billion to settle allegations of tax misconduct, including  possible criminal indictments?

See Bloomberg, Credit Suisse Said Near U.S. Tax Deal for Over $1 Billion, By Tom Schoenberg, David Voreacos and Elena Logutenkova

Also, Jack Townsend issued a report on his blog about the possibilities of such a settlement – Credit Suisse Reports (5/6/14; 5/7/14)

How will USCs and LPRs living overseas be affected?

This is a question of great importance to many of the millions of USCs and LPRs residing outside the U.S.Living Outside - all US National clients  Certainly, USC and LPR individuals with accounts at Credit Suisse are bound to be directly affected.

According to the Senate report, there were some 6,000 USCs residing outside the U.S. with accounts at Credit Suisse.  For further observations on this topic, see an earlier post – Key Take Aways from Senate Investigations re: Foreign Banks and “Offshore Tax Evasion”: U.S. Citizens Residing Overseas have Become a Focus of the Government.; Posted on March 4, 2014

Will an agreement with Credit Suisse regarding USC accounts, specifically including those who live outside the U.S. bring greater attention by the IRS and DOJ to the tax compliance of USCs and LPRs residing outside the U.S.?

See, Is the new government focus on U.S. citizens living outside the U.S. misguided or a glimpse at the new future?

Only time will tell, what type of USCs and LPRs are of most interest to the IRS and DOJ.  Will they include large numbers of individuals living outside the U.S.?  Will it go beyond USC accounts at Credit Suisse to Canadian resident account holders at Royal Bank of Canada; to British resident account holders at Barclays Bank; to Mexican resident account holders at Banamex; French resident account holders at Banpais, etc. etc. etc.?

Millions of USCs reside around the world.  See,  Coming to America. . . Accidental Americans Beware – The Law Requires a U.S. Passport!

Technology (with the help of  FATCA) has enabled the U.S. government to now readily access information of financial accounts of USCs and LPRs residing throughout the world.   See, The Catch 22 of Opening a Bank Account in Your Own Country – for USCs and LPRs    (Posted on April 30, 2014)

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