...The Swiss Federal Administrative Court has barred the Swiss Federal Tax Administration from disclosing to IRS certain bank account information of clients of Julius Baer Group Ltd. In its recent decision, the court said the IRS request for information failed to offer evidence of “tax fraud or the like,” a requirement detailed in a '96 bilateral double taxation agreement. “The Court reaffirms its case law that, under the DTA Switzerland-USA 96, administrative assistance shall not be granted for presumed tax evasion, even if high amounts are at stake,” the administrative tribunal said in its decision. “It also confirms that the mere failure to declare a bank account may be qualified – at the utmost – as a tax evasion, which is not subject to administrative assistance,” the court added. Additional details can be found athttp://www.bvger.ch/index.html?lang=en.
The Swiss Federal Administrative Court has barred the Swiss Federal Tax Administration from disclosing to IRS
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