The letter from the DOJ Tax Division provides guidance to counsel for Category 2 Swiss Banks regarding penalty reductions under the Swiss Bank Program. It outlines the standards and principles that DOJ Tax Teams will apply when considering banks' submissions for penalty reductions. The letter details the process in two stages, with specific criteria for recommending mitigation based on evidence provided by the banks. It also addresses deadlines and invites additional comments from the banks.
documents/EFTA00608962.pdf
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