U.S. Indicts Four Credit Suisse Bankers In Increasing Crackdown On Offshore Accounts: Time For Voluntary Disclosure Running Out

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On February 23, 2011, the U.S. Department of Justice announced the indictment of four Swiss bankers charged with helping U.S. taxpayers use secret accounts at a Swiss bank to evade U.S. taxes. In the indictment, the grand jury charged four bankers at an "International Bank" with conspiracy to defraud the Internal Revenue Service (IRS). Press reports indicate that the referenced "International Bank" is Credit Suisse and that the bank is cooperating with the government authorities in connection with their investigation of U.S. taxpayers' undisclosed foreign accounts.

The indictment comes on the heels of the IRS announcement of a second offshore voluntary disclosure program announced on February 9, 2011. That program, the "2011 Offshore Voluntary Disclosure Initiative" has been described by the IRS commissioner as "the last, best chance for people to get back into the system." For further information on the new 2011 IRS Offshore Voluntary Disclosure program, see our February 9, 2011, Alert, "IRS Announces New Voluntary Disclosure Program."

The International Bank's managers and bankers were charged with engaging in illegal cross-border banking that was designed to assist U.S. customers in evading their income taxes by opening and maintaining secret bank accounts at the International Bank and three other Swiss-based banks. Those three banks have been identified in the press as Bank Leumi, a large Israeli bank; and Bank Frey and Maerki Baumann, two small private Swiss banks.

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Published In: Criminal Law Updates, Finance & Banking Updates, International Trade Updates, Tax Updates

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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