According to the article:
American officials learned of Liechtensteinische Landesbank's identity and alleged role through scores of voluntary disclosures made by `wealthy Americans in recent years to the U.S. Internal Revenue Service. The disclosures, which offer reduced fines and penalties in exchange for coming forward with secret offshore accounts, require U.S. taxpayers to provide detailed information about the network of banks, trusts, shell corporations and intermediaries they have used.It has been clear for some time that the Government was picking up egregious enablers through the disclosures made in the special offshore voluntary disclosure programs. The same database of information will produce the names and skullduggery of the egregrious financial institutions in this game as well.
In a similar vein, the Wall Street Journal reports today the the "golden age of offshore tax havens may be fading out." Robert Frank, 'Gold Mine' of Data Helps Officials Clamp Down on Offshore Tax Havens (WSJ 9/10/11), here. The Gold Mine is, of course, the data mentioned in the Browning article. Here are some excerpts:
The recent tax-fraud case involving Swiss bank UBS AG has been the biggest catalyst, tax lawyers say. As part of a deal with the U.S. Justice Department, UBS agreed to hand over more than 4,000 of names of U.S. account holders. Fifteen thousand others came forward under a voluntary disclosure program of reduced penalties.
Data from those accounts enabled the IRS to create a detailed roadmap of tax evasion around the world. Rather than just account holders, the IRS now is targeting banks, law firms, trust companies and accountants suspected of creating illegal offshore structures. It is getting help from its Global High Wealth Industry Group, formed in 2009 with agents better trained in complex financial structures.
"All of this data has become a gold mine for the IRS," says Bryan C. Skarlatos, an international tax lawyer at Kostelantez & Fink. "They can finally pierce the entire offshore banking infrastructure." The rise of computerized accounts has made it much easier to find and trace accounts and assets, he added.
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"Basically, the IRS wants to make it so that if you want to hide money, you're going to have to go to a small distant island in the South Pacific where you have to paddle over in a canoe to make a withdrawal," Mr. Skarlatos said. "You have to hope your money is there when you arrive."