Last week we posted Swiss Banks Agree to Plan to End Past US Tax Evasion Issues which marked a turning point in a lengthy dispute between Bern and Washington, and opened the door for about 100 second-tier Swiss banks to turn over information about American account holders to the U.S. government.
Part of the deal requires Swiss banks to tell Washington about so-called leavers, or U.S. customers who shift assets to other countries. This disclosure will be a powerful tool for U.S. authorities, who started turning up the heat on offshore tax avoidance in 2008.
In a statement last week on the pact, the U.S. Justice Department noted that its tax enforcement activities are global and have included actions undertaken in India, Luxembourg, Israel and Caribbean countries.
The United States for five years has been aggressively pursuing U.S. citizens who have been hiding assets abroad to evade taxes.
The Swiss settlement program is only open to banks. U.S. prosecutors are hoping the renewed pressure on banks will drive U.S. taxpayers into the IRS's voluntary disclosure program, which allows taxpayers to come clean about all of their assets abroad, pay a penalty and avoid prosecution.
If a large number of Swiss banks participate in settlements, it's just a matter of time before the U.S. authorities find the U.S. person.
On August 16, a Swiss lawyer accused of helping U.S. clients hide millions of dollars in offshore accounts pleaded guilty to conspiracy to commit tax fraud in federal court in New York.
The Justice Department said last week that since 2009 it has charged more than 30 bankers and 68 U.S. account holders with violations arising from offshore banking activities. It said 54 U.S. taxpayers and four bankers and advisers have pleaded guilty, while five taxpayers have been convicted at trial.
Read more at: Tax Times blog