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.
On March 31, 2010, the U.S. and Switzerland signed a protocol to the 2009 agreement that called on Switzerland to provide administrative assistance under Article 26 (Exchange of information) of the Switzerland-U.S. income tax treaty regarding information on the U.S. clients of UBS (UBS Agreement). Although the terms of the protocol were not provided to the public, the Swiss Federal Council said that the revised UBS Agreement created the necessary legal basis for the Switzerland’s tax administration to issue final decisions on “cases regarding continued and serious tax evasion” and permitted Switzerland to comply with its obligations to the U.S. as required under international law.
If the HSBC information is provided to the U.S., the IRS would gain valuable insight from reviewing the data. It would see what types of accounts were held, in what regions, and how HSBC’s Swiss banking operation worked. About 15,000 U.S. taxpayers with offshore accounts came forward under a voluntary amnesty program last year, giving authorities a trove of information with which to hunt. All this information is likely to give the IRS and the DOJ new leads for its continued efforts to go after offshore tax cheats.
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.