Readers will recall that the IRAS has been combatting offshore banking secrecy for several years. There was a surge of interest when Switzerland's largest bank was charged with aiding tax evasion by hiding offshore accounts. The bank paid a fine and agreed to hand over data on several thousand accounts. At the same time, the IRS cracked down on accountholders. A voluntary disclosure program encouraged holders to come forward, but they had to reveal detailed information about the way their accounts were handled and who the bankers were who had assisted them. Almost 20,000 participated in the initialdisclosure initiative, and a second volunatry disclosure program is now underway.
The information gleaned from the thousands of disclosures has to have been a treasure trove for the IRS's enforcement effort. The fisc, of course, has gained even with the lesser penalties from voluntary disclosure. And there have been criminal charges filed against some offenders. Last February, four Credit Suisse bankers were indicted for conspiring to aid tax evasion. A civil action was filed in April against HSBC Holdings for information about U.S. taxpayers who may have used Indica to hide accounts. And now there will apparently be more charges against additional foreign banks, according to Steven Miller, deputy commissioner for services and enforcement, as reported by Rubin & Voreacos, IRS readies enforcement against at least one overseas bank, Bloomberg.com, June 8, 2011.
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