Clifford Chance
Beyond Switzerland: Managing Tax- Related Risks to Global Institutions Arising Out of US Person Accounts
11 May 2016
For nearly a decade, the Tax Division of the US Department of Justice and the Internal Revenue Service have been focused on investigating and prosecuting Swiss financial institutions for assisting US customers in evading US tax by maintaining unreported offshore accounts. The DOJ has acted against numerous individual institutions and private banks, demanding fines, penalties, interest, and restitution. The DOJ also has, through an agreement with the Swiss government covering the entire banking industry, accepted voluntary disclosures of US customer activity from scores of Swiss banks, resulting in additional hundreds of millions in fines. In addition, the IRS initiated a Voluntary Disclosure Program providing partial amnesty to individual taxpayers who came forward.
