Saturday, October 3, 2015
Tax Notes Today Article on What Comes Next for Non-Swiss Banks Enabling U.S. Evasion (10/3/15)
Tax Notes today has another article about offshore accounts, this one on the DOJ Swiss Bank Program and speculation about it possible expansion to non-Swiss banks. Marie Sapirie, What Comes After the Swiss Bank Program in Enforcement?, 149 TAX NOTES 12 (OCT. 5, 2015) [No link available]. I don't see anything particularly new in the article, but simply a re-cap and extension of what is already known. Of course, although DOJ Tax has not announced an extension beyond Swiss Banks, I and, I think, most practitioners think it is a no-brainer to do so. Other countries' banks played prominently in enabling U.S. taxpayer evasion, so I think most practitioners think it a logical extension of the Swiss Bank Program to have it apply to banks in other countries. There will be tweaks because DOJ Tax has learned a lot in implementing the Swiss Bank Program. But, any such action is speculation and surmise.