The Internal Revenue Service said that it would soon announce a new amnesty program aimed at encouraging wealthy Americans with hidden offshore bank accounts to come forward, declare their money and pay taxes owed.

U.S. prosecutors have charged an ex-UBS banker with tax fraud for encouraging his wealthy American clients not to disclose to U.S. tax authorities that they had money in offshore accounts.

In a recent case of United States v. J. Bryan Williams, the U.S. District Court for the Eastern District of Virginia found that the government had failed to meet its burden to establish by a preponderance of the evidence that a taxpayer willfully failed to report his interest in a foreign bank accounts that were omitted from the individual’s 2000 tax return.

On August 26, 2010, the Swiss government said it had reviewed approximately 4,450 UBS client accounts and that half of the data had already been handed over to the United States.

HSBC appears to be the next target of U.S. government in its fight against offshore tax evasion. On June 21, 2010, the Department of Justice issued letters to HSBC clients informing them that they are subject to a criminal investigation.

Just as the April 15th deadline for filing income tax returns approached, the US government announced a bunch of new cases against the taxpayers who were hiding their assets in Swiss bank accounts. The parade of cases involved at least $145 million hidden in foreign bank accounts, according to the officials.

Another UBS client pleads guilty to failure to file FBAR forms related to his Swiss account.

U.S. prosecutors prepare a new wave of UBS-related tax evasion cases against individuals, and they do it just before the April 15 tax-filing deadline.

Theft of Tax Data May Help U.S. Fight Tax Evasion

The next step in the IRS fight against offshore tax evasion may lead to the government’s use of stolen data. Tax data thefts at HSBC in Switzerland and other offshore banks are leading more whistleblowers to come forward to U.S. tax authorities, Kevin Downing, a top Department of Justice prosecutor said on March 5, 2010.

IRS Calls Offshore Voluntary Disclosure Program a Success. What if You Did Not Participate in the Program?