Justice Department Reaches Final Resolutions Under Swiss Bank Program

In a press release, the Department of Justice announced that “it has reached final resolutions with banks that have met the requirements of the Swiss Bank Program.  The Program provided a path for Swiss banks to resolve potential criminal liabilities in the United States, and to cooperate in the Department’s ongoing investigations of the use of foreign bank accounts to commit tax evasion.  The Program also provided a path for those Swiss banks that were not engaged in wrongful acts but nonetheless wanted a resolution of their status.  Banks already under criminal investigation related to their Swiss-banking activities and all individuals were expressly excluded from the Program.”

Information Received Continues to Drive Civil and Criminal Enforcement Efforts

Principal Deputy Assistant Attorney General Caroline D. Ciraolo said “We are now in the legacy phase of the Program, in which the participating banks are cooperating, and will continue to cooperate, in all related civil and criminal proceedings and investigations.  The Tax Division, working closely with its colleagues throughout the Department and its partners within the Internal Revenue Service (IRS), will continue to hold financial institutions, professionals, and individual U.S. taxpayers accountable for their respective roles in concealing foreign accounts and assets, and evading U.S. tax obligations.”

“Offshore compliance remains an important area of tax administration,” said IRS Large Business & International Division (LB&I) Commissioner Douglas O’Donnell.  “We are evaluating incoming information to detect accountholders who have evaded reporting overseas assets and income, and we are using this information to further untangle the web of financial institutions and intermediaries helping with this evasion.  We have expanded our investigations to other regions of the world, and we will continue to apply these techniques to help protect honest taxpayers.”

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