Another Swiss bank has agreed to pay a fine to the DOJ to avoid prosecution for assisting US citizens to avoid paying taxes. Piguet Galland & Cie SA is going to pay $15.365 million to settle its case. http://www.bloomberg.com/news/articles/2015-10-23/piguet-galland-will-pay-15-4-million-in-u-s-tax-settlement-ig3vkpez. Bloomberg reports that this is the 43rd such settlement reached by between banks and US authorities this year alone.
As reported by Law360: “To avoid prosecution, banks must agree to disclose all of their cross-border activities, provide account-by-account information for accounts in which U.S. taxpayers have a direct or indirect interest, provide information on other banks transferring funds to secret accounts or accepting funds from closed secret accounts, end their relationships with account holders who refuse to comply with U.S. laws, and pay penalties.” http://www.law360.com/articles/718179/swiss-bank-to-pay-15m-under-doj-tax-evasion-program (subscription required).
Short version is: if you or your clients have bank accounts abroad that are “secret,” you should probably think about disclosing them in compliance with IRS rules (and with the help of a good lawyer). https://www.irs.gov/Individuals/International-Taxpayers/Offshore-Voluntary-Disclosure-Program-Frequently-Asked-Questions-and-Answers-2012-Revised. With the information that the banks are sharing, IRS CI agents are gaining new tools to track down and prosecute U.S. tax cheats around the world. Absent appropriate voluntary disclosure, any US taxpayer with a “secret” account abroad should consider themselves a potential target.