Tax Treaty Case Law around the Globe 2014
1. Aufl. 2015
Besitzen Sie diesen Inhalt bereits,
melden Sie sich an.
oder schalten Sie Ihr Produkt zur digitalen Nutzung frei.
S. 315Chapter 31 Switzerland: Group Request under the Switzerland-United States Tax Treaty
Stefano Bernasconi and Michael Beusch
31.1. Introduction
According to the US Internal Revenue Service (IRS), the Credit Suisse Group AG (CS), Switzerland's second largest bank, and its subsidiaries and affiliates advised its clients on how to set up fraudulent schemes, which caused illegal and substantial reduction in the amount of tax paid by the US clients with respect to income or gains derived from their US or foreign investments.
In its request for mutual administrative assistance, the IRS mentioned, inter alia, the following practices of CS:
CS maintained representative offices in the United States that were used to facilitate transactions by its clients vis- à -vis their undisclosed foreign accounts.
CS employees assisted the US clients by moving currency to and from Switzerland.
The US clients were advised on the use of domiciliary companies and other arrangements in jurisdictions throughout the world to conceal their beneficial ownership of the accounts.
The background of this request was the ongoing tax dispute between the United States and Switzerland. On , Switzerland agreed to a...