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  #21  
Old 16.12.2014, 12:35
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Re: IRS Coming to Switzerland - literally!

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My current IRS rage:

Received a letter in yesterday's mail, dated Nov 24, 2014 indicating I had underpaid my taxes by several dollars. The letter, posted from the UK, arrived in my mailbox on Dec 13, 2014.

Due date before additional penalties are incurred? Dec 15, 2014.


I once received a letter from them that was post marked (in the US) after the due date for the payment.
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  #22  
Old 16.12.2014, 14:38
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Re: IRS Coming to Switzerland - literally!

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I just gave my first and initial. Although, I've been compliant one never knows if you could end up on a watchlist for an audit
Did the same once but with Swiss tax authorities. Got an answer by post, sent registered letter to my name and address.

No kidding.
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  #23  
Old 19.12.2014, 12:20
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Re: IRS Coming to Switzerland - literally!

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http://bern.usembassy.gov/federal_tax_law.html

"The U.S. Embassy is pleased to announce a visit and presentation by the Internal Revenue Service (IRS). The American Women’s Club of Zurich (AWCZ) has graciously agreed to host the U.S. Embassy and the IRS at their clubhouse on January 26-27, 2015.

"In the event that the IRS has not done its homework, it should note that Switzerland has a strict law on foreign agents operating on Swiss territory, Swiss Criminal Code Art. 271:

“Art. 271
Unlawful activities on behalf of a foreign state
1. Any person who carries out activities on behalf of a foreign state on Swiss territory without lawful authority, where such activities are the responsibility of a public authority or public official,
- any person who carries out such activities for a foreign party or organisation,
- any person who encourages such activities,
is liable to a custodial sentence not exceeding three years or to a monetary penalty, or in serious cases to a custodial sentence of not less than one year.”

http://www.admin.ch/ch/e/rs/311_0/a271.html

In a nutshell, IRS agents and those responsible for organizing these sessions could be arrested unless prior legal approval has been obtained."

Now wouldn't that be a nice Christmas present.
Using the "Acting for a Foreign State" law against the IRS agents might be appropriate but it is usually reserved for cases of suspected espionage. Another law that could be applied against the visiting IRS agents is the Swiss "Foreigner Law" (Ausländergesetz). It has been used effectively against foreigners working as prostitutes, drug dealers, running illegal gambling operations and just plain working illegally ("Schwarzarbeit").

It has also been applied against managers and other facilitators who hired or enabled the illegal work by foreigners. In this case, it could be applied against the Board of the American Women's Club of Zurich.

The Zurich police should plan on bringing a large police van to collect the miscreants.

Some cases where the Foreigner Law was applied:
https://kriminalitaetschweiz.wordpre...slandergesetz/
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  #24  
Old 19.12.2014, 12:39
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Re: IRS Coming to Switzerland - literally!

Expect Zurich to be a ghost town on that day.

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  #25  
Old 19.12.2014, 12:49
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Re: IRS Coming to Switzerland - literally!

"Would you like fries with your handcuffs?"
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  #26  
Old 19.12.2014, 15:59
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Re: IRS Coming to Switzerland - literally!

...or some radioactive chocolate? Remember (credit The Local) the U.S. FDA "visiting" in 2012:

“The fact that a foreign authority is involved in our Swiss businesses is unseemly,” Daniel Bloch, of Chocolats Camille Bloch, told Handelszeitung, the German-language business journal.

The newspaper has discovered that the US Food and Drug Administration (FDA) plans to inspect 21 chocolate factories and 18 dairies in Switzerland.

The FDA contends that imported food could be contaminated chemically or even in a radioactive way.

Handelszeitung said Swiss chocolate makers are astonished to be subjected to such screening from a foreign country.

So, first it's the FDA, then the CIA and now the IRS......who's up next?

Nothing like an all expense paid trip to CH, complements by the U.S. taxpayer!
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  #27  
Old 20.12.2014, 23:14
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Re: IRS Coming to Switzerland - literally!

The question is whether the activities planned by the IRS during their visit to Switzerland would qualify under a "Business Visitor" exemption. Fragomen, a law firm, lists allowable activities for a "Business Visitor" to Switzerland which do not require a work permit and/ or visa:

"BUSINESS VISITORS

Business Visit Defined – A “business visit” is generally a short-term trip taken to conduct business activities for which work authorization is not required in the destination country. Once a foreign national requires work authorization, she or he is no longer considered a “business visitor” from an immigration perspective, even though the foreign national may be making a very short “visit” to a country for what she or he considers to be “business” purposes.

Allowable Activities – In Switzerland, business visitors must generally limit their activities to the following:
  • Attending business meetings or discussions, including representing their overseas employer in meetings with clients
  • Attending contract negotiations
  • Hosting or attending business presentations
  • Making sales calls to potential Swiss clients, provided that the visitor represents a commercial entity outside of Switzerland
  • Attending seminars or "fact-finding" meetings
If a business trip, even a very brief one, will involve activities other than those outlined above, a work permit and/or visa will typically be required."

Planned IRS activities in Switzerland:
The IRS agents plan to conduct two types of activities while in Switzerland:
a. Give a presentation on US tax law to interested parties.
b. Conduct one-on-one tax consultation sessions with US taxpayers.

Just an opinion:
The presentation would probably be exempt under Business Visitor "Allowable Activities" but the one-on-one tax consultations would not be since this activity is not listed above. The IRS agents should consult competent counsel and probably obtain a work permit and/ or visa prior to their arrival in Switzerland to avoid possible arrest by the Swiss migration authorities.

http://www.fragomen.com/newsresource...maries&news=49
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  #28  
Old 22.12.2014, 11:23
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Re: IRS Coming to Switzerland - literally!

WikiLeaks published two confidential CIA documents yesterday which are rather informative:

1) CIA Assessment for Surviving Secondary Interviews
2) CIA Advice for Operatives Infiltrating Schengen

Regarding Schengen, the CIA points out that its operatives should have minimal worries as Schengen border controls are focused on detecting illegal immigrants and terrorists and not on foreign secret agents.

Switzerland is part of Schengen and there are probably a significant contingent of CIA as well as other US agents performing illegal activities here.

We need to be alert for the presence of foreign agents operating in Switzerland. If you see something, say something, i.e., call the police immediately.

https://wikileaks.org/cia-travel/press-release.html

https://wikileaks.org/cia-travel/

As The Local reported, German police recently arrested three Turkish intelligence operatives who were spying on Turkish citizens and Turkish organizations in Germany:

http://www.thelocal.de/20141219/thre...gents-arrested
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  #29  
Old 28.12.2014, 19:08
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Re: IRS Coming to Switzerland - literally!

"Inside Paradeplatz" picked up the story of the IRS agents coming to Switzerland. The blogger thinks the purpose of the visit is for the IRS to mark its conquered territory, similar to what gangs do. Below is a translation courtesy of Isaac Brock Society:

“US Tax Police: Command Performance by the Victors in Zurich

Officials from the Internal Revenue Service to consult voluntarily – on the soil of the “armpit” district in the city of Zurich – Swiss Federal Government in Bern finds nothing wrong with it.

24/12/2014 by Lukas Hässig

“The US Internal Revenue Service (IRS) is Coming to Switzerland”, says the invitation of the US Embassy in Bern for a two-day event at the end of January in Zurich’s district 4, a blue collar and nightlife area.

The idea of the event is to call US taxpayers to conscience to show that they have power over the world for monetary obligations.

On the US Embassy website, which is promoting the event, is a detailed list of who might owe something to Uncle Sam.

The occasion and the information campaign around it remind you of a victorious power preaching fire and brimstone on conquered territory.

The basis for this is the genuflection by Switzerland in August 2013. The so-called “US Program for Banks” committed the financial center to comprehensive fines and disclosure of all employees.

The United States will use the money for its debts and investments and the names from the banks to help them hunt down the tax evaders.

The big tax war was decided with the “deal” in August 2013. Since then, Switzerland is astonished with the consequences.

Banks that have taken their place in the so-called guilty category 2, note that they are being bled to death. Although they may have had only a few US black money accounts, they have betrayed their people and will pay fines.

In addition, an eternal chokehold threatens. Now some banks are trying to free themselves from the embrace by jumping into the not-guilty category 3.

The maneuvers of the Swiss financial institutions do not seem to impress the strategists of the superpower. Their campaign continues as if they own the territory of Switzerland.

On January 26, 2015 specialists are to fly from the IRS office in Paris to explain US tax requirements at the Zurich event.

According to the announcement on the US Embassy website, IRS officials will provide a “limited number of 15-minute private consultations on individual tax matters”.

Nearly 50 people have been registered in a single dedicated Doodle registration for such private consultations. Around 50 interested people also signed up for the “public presentation on tax-related information” for US taxpayers.

At the Swiss Federal government in Bern, the advance of the IRS is not an issue. Neither the Swiss Federal Justice Department nor the Swiss Federal Tax Administration see a violation of Swiss law.

The Attorney General, in charge of national criminal matters, waved off. “Pure consultations are not criminally relevant,” said a spokeswoman.

The IRS occasion in District 4 sheds light on the self-image of the US in tax matters. “You Can Run But You Cannot Hide”. Washington is calling its flock.

No matter where one lives: Americans remain taxable, whoever has any connection to the land of opportunity.

This may be a birth on US soil, a work permit, a longer period of study or of course citizenship.

With global control in place, the Swiss banks are now willing helpers for the US sheriff.

This is the case of a Swiss, who officially returned his “green card”, i.e., work permit, in early 2013 at the US Mission in Lima, Peru.

Shortly thereafter, he was asked by UBS for any US connections. The customer checked the box for all questions regarding America with “No”.

Nevertheless, the Bank in 2014 asked him to submit a tax certificate. Because he did not respond, UBS told him in November to sell all of his assets and will block his accounts by January 2015.

As a reason the Swiss bank gave to its customers that he was subject to relevant regulations as a “US Person residing outside the United States”.

The trigger was the Foreign Account Tax Compliance Act (FATCA). With this Act, the banks around the globe collect all asset information from “US Persons” for the attention of the American world power.

FATCA and earlier disclosures for Americans abroad make all stakeholders transparent citizens.

Such is the case is from a Swiss perspective: Whether a customer cuts the ropes to the US, he remains within reach of the Americans.

Thanks kindly to UBS & Co.”

http://insideparadeplatz.ch/2014/12/...macht-zuerich/
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  #30  
Old 08.01.2015, 15:05
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Re: IRS Coming to Switzerland - literally!

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Tina Masuda is (or was) accredited as the IRS Representative in Paris, which means she has diplomatic immunity in France and travels on a diplomatic passport. That passport gives her no immunity in Switzerland, except that as a matter of diplomatic courtesy she would (as a matter of Foreign Ministry discretion) enjoy functional immunity for her official acts.

She will undoubtedly be discreet in the exercise of her function within Switzerland.

If (and only if) the Embassy in Bern notified the Foreign Ministry of her expected arrival and asked for her inclusion on the diplomatic list, she would enjoy full immunity. In difficult countries (the old USSR, many countries in Africa, etc.) it is State policy to notify the host country's foreign ministry of every official TDY visit, however brief, to assure immunity. That ensued from a contretemps in Benin where TDY communicators were arbitrarily arrested while driving out of the country in the 1970s.

IRS attachés have little or no policy responsibility and are there to provide limited taxpayer assistance and to coordinate with host country tax authorities on "Competent Authority" treaty issues, including exchange of taxpayer data.
The IRS Tax Attaché in Paris is Aziz Benbrahim. A quick Google search shows that he is accredited in a number of European, African and Middle East countries, although I did not find him as accredited in Switzerland.

As of several years ago, according to a Google search, the IRS office in Paris had five employees. It could be expected that most will be traveling to Switzerland to handle the 40+ one-on-one "consultations" with US taxpayers and also the presentation at the AWCZ.
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  #31  
Old 15.01.2015, 13:49
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Re: IRS Coming to Switzerland - literally!

Bloomberg writes that the IRS offices in Paris, London and Frankfurt will be closed and the personnel returned to the US:

"The Internal Revenue Service is closing the last of its overseas taxpayer-assistance centers, saying that years of budget cuts have forced it to end a popular program designed to help U.S. citizens living or traveling abroad.
The closing of IRS offices attached to U.S. Embassies in London and Paris, as well as the consulate in Frankfurt, will allow the agency to reassign about a dozen employees to its domestic offices and save about $4 million a year, the IRS said in a statement.
After workforce reductions at the IRS, Commissioner John Koskinen warned last month that refund checks may be delayed for millions of taxpayers this filing season.
For decades, the IRS has stationed employees in embassies and consulates around the globe to assist American expatriates with their tax issues and help inspect the foreign operations of U.S. companies in cases involving possible civil violations of tax code. In 1993, the IRS had staff members attached to more than a dozen embassies around the world, from Riyadh and Ottawa to Singapore and Caracas. By last year, that number was reduced to four, and in November the IRS closed its Beijing office."

http://www.bloomberg.com/news/2015-0...e-centers.html

The planned IRS trip to Zurich is looking like a last-hurrah junket before the Paris staff is repatriated.
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  #32  
Old 08.04.2015, 19:42
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Re: IRS Coming to Switzerland - literally!

The IRS offices in Paris, London and Frankfurt are being closed and their work will be transferred to an IRS call center in Philadelphia. It looks like a horror story:

"Frank Spadea manages an IRS call center in Philadelphia, where employees sit in a cubicle farm and field questions from Americans in foreign countries. His group used to have 51 employees; it’s down to 17. Of those, he expects at least two to retire this year, and they won’t be replaced. “It’s been seven or eight years since I’ve been able to hire,” he says. Meanwhile, his staff has been overwhelmed with calls this year from Americans overseas who are confused about extra information they’re supposed to furnish under the 2010 law combating tax cheating abroad. “They are calling like crazy about that,” says Donna White, a customer service representative in the office. “You kind of get burnt out.” "

http://www.bloomberg.com/news/featur...nd-overwhelmed
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