Jack Townsend offers this blog on Federal Tax Crimes principally for tax professionals and tax students. It is not directed to lay readers -- such as persons who are potentially subject to U.S. civil and criminal tax or related consequences. LAY READERS SHOULD READ THE PAGE IN THE RIGHT HAND COLUMN TITLE "INTENDED AUDIENCE FOR BLOG; CAUTIONARY NOTE TO LAY READERS." Thank you.
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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.
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