The Tax Division's top litigation priority is the concerted civil and criminal effort to combat the serious problem of non-compliance with our tax laws by U.S. taxpayers using secret offshore bank accounts - a problem that a 2008 Senate report concluded costs the U.S. Treasury at least $100 billion annually. As part of a deferred prosecution agreement the Tax Division negotiated in 2009 with UBS AG, Switzerland's largest bank, as well as a 2009 agreement negotiated among the US, UBS, and the Swiss government to settle a civil summons enforcement proceeding brought by the Tax Division, the IRS is receiving, from UBS and from the Swiss, account information about thousands of the most significant tax cheats among the U.S. taxpayers who maintain secret Swiss bank accounts.
The prosecution results so far have been encouraging: To date, approximately 150 investigations of offshore-banking clients have been initiated, of which 36 client cases have been charged, with 31 guilty pleas having been entered, 2 convicted after trial, and 5 awaiting trial. A number of facilitators who helped clients hide assets offshore at UBS and other banks have been indicted, resulting in 13 bankers and 2 attorneys being charged and awaiting trial, and one advisor and one banker being charged and convicted. In addition, investigations have been opened into numerous additional offshore banks across the world.
But the outcome cannot be measured in litigation results alone. This enforcement effort has dealt fabled Swiss bank secrecy a devastating blow and provided tools that should yield information on thousands of additional U.S. offshore account holders who have undisclosed accounts at UBS and other banks. Moreover, the publicity surrounding the Tax Division's enforcement action and the subsequent settlement has already produced dramatic behavior changes. The IRS credits these two agreements with prompting an unprecedented number of taxpayers - nearly 18,000 in the 18-month period concluding in February 2011, in contrast to the fewer than 100 typical in previous years - to "come in from the cold" and voluntarily disclose to the IRS their previously hidden foreign accounts and also to agree to pay hundreds of millions of dollars to the U.S. Treasury. The continuing prosecutions of foreign-account holders and their facilitators created a favorable atmosphere for the IRS to roll out a second voluntary disclosure program on February 8, 2011. Also, buoyed by our success in the United States, a number of European countries have pressed Switzerland to provide similar account information for their nationals.
By strategically timing its voluntary disclosure programs in tandem with the Tax Division's civil and criminal litigation efforts, the IRS has been able to obtain significant additional information about those who have helped to facilitate tax fraud -- information that is extremely important to tax administration and is expected to lead to additional criminal investigations. Although hard to measure, the fact that foreign bank secrecy is no longer "secret" should improve voluntary compliance by dissuading many other taxpayers from attempting to maintain hidden offshore accounts in the first instance. Put simply, the word is out that placing assets in foreign accounts no longer provides the protection from disclosure it once did.
Offshore Compliance Initiative News
Indictments, Pleas, Sentencings, and
Other Developments
July 30, 2012
California UBS Clients Sentenced to Prison for Hiding Assets in Secret Bank Accounts Around the World |
June 15, 2012
Three Tax Return Preparers Charged with Helping Clients Evade Taxes by Hiding Millions in Secret Accounts at Two Israeli Banks |
May 30, 2012
South Florida Retired Businessman Pleads Guilty to Failing to Disclose Assets Held in Swiss Banks |
February 2, 2012
Swiss Bank Indicted on U.S. Tax Charges |
January 30, 2012
UBS Clients and Tax Attorney Indicted in Phoenix for Hiding Assets in Secret Foreign Bank Accounts |
January 3, 2012
Manhattan U.S. Attorney Charges Three Swiss Bankers with Conspiring to
Hide More Than $1.2 Billion in U.S. Taxpayer Accounts from the IRS |
December 7, 2011
Client of UBS and Swiss Cantonal Bank Indicted for Conspiracy to Defraud the IRS |
November 17, 2011
HSBC India Client Indicted for Tax Evasion and Failing to Report Foreign Bank Accounts |
August 3, 2011
UBS Client Pleads Guilty to Filing False Tax Return |
August 2, 2011
Former UBS Banker Charged with Helping U.S. Taxpayers Use Secret Swiss Bank Accounts to Evade U.S. Taxes |
July 21, 2011
Swiss International Bank's Former Head of North America Offshore Banking, Others Charged with Conspiracy |
July 21, 2011
Swiss Financial Advisor Indicted for Conspiring with More Than 60 U.S. Taxpayers to Hide More Than $184 Million in Swiss Bank Accounts |
June 28, 2011
HSBC India Client Indicted for Filing False Tax Returns and Failing to Report Foreign Bank Account |
June 20, 2011
California UBS Clients Plead Guilty to Hiding Assets in Secret Swiss Bank Account |
May 24, 2011
New Jersey UBS Client Sentenced for Failing to Report More Than $1 Million in Swiss Bank Account |
May 23, 2011
New Jersey UBS Client Sentenced for Failing to Report More Than $750,000 in Swiss Bank Account |
May 19, 2011
Bank Director Charged with Hiding Foreign Assets |
April 13, 2011
New York Woman Pleads Guilty to Filing a False Tax Return; Did Not Report Her HSBC India Bank Account Held $8.3 Million |
April 11, 2011
New Jersey Businessman Pleads Guilty to Conspiring to Conceal Offshore Bank Accounts from the IRS |
April 7, 2011
Justice Department Asks Court to Allow IRS to Seek HSBC India Bank Account Records |
March 14, 2011
UBS Client Sentenced in San Diego for Hiding Assets in Secret Bahamian and Swiss Bank Accounts |
March 8, 2011
Former Ohio Man Pleads Guilty to Failing to Report His Foreign Bank Account at UBS in Switzerland |
March 4, 2011
Former UBS Client Sentenced for Hiding Millions in Offshore Bank Accounts |
February 23, 2011
Four Swiss Bankers Charged with Helping U.S. Taxpayers Use Secret Accounts at Swiss Banks to Evade U.S. Taxes |
February 4, 2011 - S.D. Florida
Miami Beach Hotel Developers Sentenced for Tax Fraud |
December 22, 2010
Former UBS Banker Pleads Guilty to Helping American Client Conceal Assets Offshore |
November 19, 2010
California UBS Client Indicted for Hiding Assets in Secret Swiss Bank Accounts |
November 18, 2010
California UBS Client Charged with Hiding Assets in Secret Swiss Bank Account |
July 15, 2010
Swiss Lawyer Indicted for Helping to Hide Swiss Bank Accounts and Monies Returned to U.S. Clients |
May 26, 2010
Miami Beach Hotel Developers Indicted and Charged with Tax Fraud |
April 23, 2010
Former UBS Client Sentenced for Hiding $10 Million in Offshore Bank Accounts |
April 15, 2010
Miami Beach Hotel Developers Charged with Conspiring to Defraud United States |
April 15, 2010
Seven UBS Clients Charged with Hiding Over $100 Million in Secret Swiss Bank Accounts to Defraud the IRS |
April 13, 2010
Former UBS Client Pleads Guilty to Hiding Assets in Secret Offshore Bank Accounts |
April 12, 2010
UBS Client Pleads Guilty to Failing to Report Over $1 Million in Swiss Bank Accounts |
February 16, 2010
Virginia Doctor Pleads Guilty to Conspiracy Involving Undeclared Swiss Bank Account |
February 4, 2010
Former UBS Client Pleads Guilty to Hiding $10 Million in Offshore Bank Accounts |
November 17, 2009
Justice Department & IRS Announce Results of UBS Settlement & Unprecedented Response in Voluntary Tax Disclosure Program |
October 5, 2009
Seattle Area UBS Client Pleads Guilty to Filing a False Tax Return |
September 25, 2009
UBS Client Pleads Guilty to Failing to Report $6.1 Million in Swiss Bank Accounts |
August 21, 2009
Former UBS Banker Sentenced to 40 Months for Aiding Billionaire American Evade Taxes |
August 20, 2009
Swiss Banking Executive and Swiss Lawyer Charged with Conspiring to Defraud the United States |
August 19, 2009
Remarks by IRS Commissioner Doug Shulman on UBS |
August 19, 2009
U.S. Discloses Terms of Agreement with Swiss Government Regarding UBS |
July 28, 2009
UBS Client Pleads Guilty to Filing False Tax Return, Hid $8 Million in Secret Swiss Bank Accounts |
June 25, 2009
UBS Client Pleads Guilty to Filing False Tax Return |
April 15, 2009
Department of Justice Asks Court to Serve Summons for Offshore Records |
April 14, 2009
UBS Client Pleads Guilty to Filing False Tax Return Hid Assets Worth $3 Million in Secret Swiss Bank Account |
April 2, 2009
UBS Client Charged with Filing False Tax Return |
March 4, 2009
Statement of John DiCicco, Acting Assistant Attorney General for the Tax Division, before the Permanent Subcommittee on Investigations, Committee on Homeland Security and Government Affairs of the U.S. Senate at the hearing entitled "Tax Haven Banks and U.S. Tax Compliance - Obtaining the Names of U.S. Clients with Swiss Accounts." |
February 19, 2009
United States Asks Court to Enforce Summons for UBS Swiss Bank Account Records |
February 18, 2009
UBS Enters into Deferred Prosecution Agreement |