The United States and Switzerland have announced a deal to end the long-running tax evasion dispute that has embroiled the Swiss banking industry for the past several years. A DOJ press release announcing the deal is available here. Under the terms of the program, participating participating Swiss banks will be required to:
— Agree to pay substantial penalties
— Make a complete disclosure of their cross-border activities
— Provide detailed information on an account-by-account basis for accounts in which U.S. taxpayers have a direct or indirect interest
— Cooperate in treaty requests for account information
— Provide detailed information as to other banks that transferred funds into secret accounts or that accepted funds when secret accounts were closed
— Agree to close accounts of account holders who fail to come into compliance with U.S. reporting obligations
Banks meeting all of the above requirements will be eligible for non-prosecution agreements. Banks currently under criminal investigation related to their Swiss banking activities, and all individuals, are expressly excluded from the program.
We will have more analysis of this landmark announcement shortly.