DOJ Program for Swiss Banks, here.
Links to the DOJ Announcements:
- Press release (8/29/13), here.
- Joint Statement between the U.S. Department of Justice and the Swiss Federal Department of Finance (8/29/13), here.
- Signed Joint Statement and Program, 8/29/13 (8/29/13), here.
- DOJ Tax comments about the Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks (11/5/13), here.
- DOJ Tax Further Comments about the Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks (6/5/14), here.
- IRS Foreign Financial Institutions or Facilitators, here. This lists the foreign financial firms and other facilitators (I often call these enablers) of U.S. tax evasion that have been plublicly identified as having some U.S. Government initiative (e.g., indictment or subsequent action, deferred prosecution agreement, nonprosecution agreement, John Doe Summons, etc.). The foreign financial firms and other facilitators will have consequences that result in the public disclosure. U.S. taxpayers having accounts with the foreign financial firms on that list will be required to pay a 50% OVDP miscellaneous offshore penalty rather than the 27 1/2% penalty normally required. The list is supplemented by the IRS as new public disclosures are made. (Note that this bump to 50% applies only if the taxpayer in OVDP does not opt out; if the taxpayer opts out, the taxpayer is effectively in an audit regime where any and all tax and FBAR penalties may apply for open years, so that a taxpayer might get a better or worse result on opt out.)
- I keep a list of the Swiss Banks that I am aware of that join the program. The list is part of the spreadsheet I keep on the page above titled "Offshore Charges / Convictions Spreadsheet." Click here to go to that page. The spreadsheet is large. For bank date, I have two worksheets -- one with the bank data and the other with the bank data analysis. [Note, I only publish this spreadsheet periodically; I do separately publish blog entries as DOJ Tax announces Swiss Banks in category 2 reaching NPAs and provide the cumulative statistics each time I publish the blog.]
- List of 14 Swiss Banks Under Criminal Investigation (Federal Tax Crimes Blog 3/9/14), here. I update this list as I get information, but I think by now that it is pretty accurate. Credit Suisse has resolved its criminal investigation, but no resolution of the others has been announced.
- US Tax Program (seems to be periodically updated and sortable), here. (Also has other pages of interest.)
Statistics on Swiss Category 2 Banks Achieving NonProsecution Agreements (NPAs). Each time DOJ announces that one or more Swiss category 2 banks have achieved NPAs under the program, I create a blog entry reporting the announcement and, with each blog entry, provide updated statistics for the cumulative results. I also present the individual bank agreements and the combined statistics in my spreadsheet, here.
Key Federal Tax Crimes Blog Entries on various facets of the program (in reverse chronological order):
- US DOJ Swiss Bank Program Categories 3 and 4 Comments (2/4/16; 2/7/16), here.
- My List of Category 2 Banks Obtaining NPAs (1/28/16; 1/30/16; 2/7/16), here.
- Bank Julius Baer, a Category 1 Bank, Enters Deferred Prosecution Agreement with Payment of $547 Million (2/4/16), here.
- Status of the NPAs and DOJ/IRS Mining of the Fruits of the NPAs (12/15/15), here.
- Great Graphic on U.S. DOJ Swiss Bank Program Results (10/11/15), here.
- Swiss Banks' Requests to U.S. Depositors for Waivers and Proof of Entry Into OVDP (6/11/14), here.
- Reminder: Category 2 Banks Will Serve Up Their U.S. Depositors (6/11/14), here.
- Should Swiss Banks Committing U.S. Tax Crimes Pay for Their Conduct? (5/7/14), here.
- U.S. Expects the Swiss Bank Initiative to Produce Information on Account Holders and Bank Professionals (3/19/14), here.
- DOJ Tax AAG Keneally Reports on Swiss Banks Joining DOJ Swiss Bank Program (1/27/14; 1/28/14), here.
- Some Swiss Banks Spin Their Self-Identification as Category 2 Banks (1/2/14), here.\