Tuesday, March 16, 2010

Another Foreign Bank in the U.S. Government Sights

A series of news articles appear this morning centered around a statement made by the IRS Special Agent in Charge of the Tampa Field Office. The key items are:

1. The U.S. will soon go against another foreign bank for the "the same behavior that got UBS in trouble." The timing is likely to be timed to have maximum publicity effect during this return filing season (a common gambit to squeeze the maximum deterrent effect out of the prosecution), by reminding U.S. taxpayers of their obligations on 1040 and the FBAR due 6/30/10.

2. Further "tax evasion" prosecutions are likely to be brought based on the information gathered from the voluntary disclosures. Presumably, the prosecutions will be of others than the taxpayers making the voluntary disclosures. She is quoted as saying these cases will come "in waves over the next six to eight months." The voluntary disclosure information will "be a source of cases for years for us." My experience is that the principal information of misbehavior in the voluntary disclosures relates to the enablers rather than other taxpayers who did not make voluntary disclosures.

3. She notes that at least l2,000 have come in since the closing of the formal voluntary disclosure initiative on October 15, 2009, and more are coming.

4. The articles quote unnamed lawyers who suggest that the U.S. may have it sights on information that the French obtained on HSBC clients, by making a treaty request to the French.

5. The articles mention the Swiss Government plan to seek legislative approval to make the disclosures required by the U.S. / Swiss / UBS agreement.

See the Reuters version here.

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