OVDP: Definition of Willful Left Broad

Jennifer Best of the IRS stated that the IRS has deliberately refrained from offering a lot of examples about what constitutes willful failure to disclose offshore assets.  Taxpayers are only allowed to use the Internal Revenue Service's streamlined offshore voluntary disclosure program when they have failed to report foreign income or foreign financial accounts or assets, if they can certify that their failure to do so was non-willful.  Every taxpayer has a unique set of circumstances, therefore, definition of the term of "Willful" was intentionally left broad.

Credit Suisse Is Charged by DOJ

The U.S. filed charges today against Credit Suisse in Virginia for conspiring to help American taxpayers evade  taxes through the use of secret offshore accounts.  The charges were filed as an information indictment that means the defendant agreed to the form of the information indictment pre-filing.  Practically speaking, because an information was filed, it indicates that Credit Suisse and the U.S. have already negotiated a plea agreement; however, it is still subject to the Court accepting the plea and then entering a form of sentence/punishment.