Since the beginning of February one Swiss bank (Wegelin & Co.) has been indicted and another Swiss bank (Julius Baer Group)  announced that it may face possibly significant financial penalties for allegedly helping some of their American clients evade United States income taxes and FBAR filings. Also this week, the New York Times reported that France, Germany, Italy, Spain, and Britain agreed to support United States efforts to identify offshore accounts held by Americans.
Today, the New York Times published an editorial entitled “The Fight Against Tax Evasion” approving the pressure the United States is placing on Switzerland and its banks to release the names of potential American tax-evaders. The editorial concludes: “If Switzerland stonewalls, the Justice Department can indict banks that benefit from tax evasion and seize their assets in the United States, moves that could put them out of business. At some point, the Swiss government will find that result a lot more costly than handing over information on American tax cheats.”
It seems clear that the IRS is gearing-up for a crackdown on tax-evaders who have not accurately reported their foreign-source income and their foreign bank and brokerage accounts. We have written an article that “connects the dots” and provides an analysis of recent events. Our article also demonstrates how our tax boutique has the experience to help taxpayers minimize their taxes and penalties and avoid criminal prosecution.
 David Voreacos, Swiss Bank Wegelin Charged in U.S. With Aiding Tax Evasion, Bloomberg, Feb. 3, 2012. Available at http://www.bloomberg.com/news/2012-02-02/swiss-private-bank-wegelin-co-charged-in-u-s-with-aiding-tax-evasion.html
 Anita Greil, Julius Baer Expects Fine in Tax Probe, Wall St. J., Feb. 7, 2012. Available at http://online.wsj.com/article/SB10001424052970204136404577206512065652938.html
 David Jolly and Brian Knowlton, 5 European Nations Agree to Help U.S. Crack Down on Tax Evasion, N.Y. Times, Feb. 9, 2012. Available at http://www.nytimes.com/2012/02/09/business/global/5-european-nations-agree-to-help-us-crack-down-on-tax-evasion.html
 Editorial, The Fight Against Tax Evasion, N.Y. Times, Feb. 10, 2012. Available at http://www.nytimes.com/2012/02/10/opinion/the-fight-against-tax-evasion.html?_r=1&ref=todayspaper