The National Taxpayer Advocate (NTA) has issued a Taxpayer Advocate Directive , complaining about unfair treatment of certain participants in the 2009 Offshore Voluntary Disclosure Program (OVDP). It appears that the NTA shared the same frustration with the OVDP that many tax practitioners, including our tax attorneys, have felt over the infamous Q&A 35 published by the IRS in the Frequently Asked Questions and Answers for the 2009 program.

On January 3, 2012, the U.S. Attorney’s Office for the Southern District of New York charged three Swiss bankers with hiding more than $1.2 billion in U.S. taxpayer accounts from the IRS. The announcement was made by Preet Bharar, the Manhattan U.S. Attorney.

IRS has put in place a program aimed at auditing taxpayers who did a so called “quiet disclosure” — those who chose not to make a voluntary disclosure, but rather chose to quietly file amended tax returns and FBARs.

Credit Suisse AG, the second largest bank of Switzerland, has notified some of its U.S. clients that it will disclose their identities and account details to the Internal Revenue Service.

The IRS has extends the deadline for the 2011 Offshore Voluntary Disclosure Intitiative (OVDI) to September 9, 2011 (from the original date of August 31, 2011). Further, the IRS has clarified what information needs to be provided by September 9, 2011, in the event that all the documents required under the OVDI are not ready to be provided by that date.

The IRS is reminding taxpayers that the deadline for the 2011 Offshore Voluntary Disclosure Initiative (OVDI) will expire on August 31, 2011.

On Wednesday, July 6, 2011, the Swiss government adopted standards on banking secrecy laid out by the Organization for Economic Cooperation and Development, or OECD, which will allow foreign authorities to pursue citizens suspected of using hidden Swiss accounts for tax evasion.

The Department of Justice and the Internal Revenue Service (IRS) announced on June 28, 2011, that Dr. Arvind Ahuja of Wisconsin was indicted on four counts of willfully filing materially false tax returns and four counts of failing to file Reports of Foreign Bank and Financial Accounts (FBARs).

U.S. government decided to prosecute a taxpayer who made a so-called “quiet disclosure” of his offshore account at HSBC.

U.S. Department of Justice and Internal Revenue Service announced that four Swiss bankers, all working at some point for Credit Suisse Group, were indicted by a federal grand jury in the Eastern District of Virginia and charged with conspiring with other Swiss bankers to defraud the United States.