The Latest DOJ Offshore Enforcement Scorecard

As we have noted in prior posts (see here), the Justice Department’s website maintains a real time “scorecard” of its efforts to clamp down on offshore tax evasion through criminal prosecutions.  The DOJ’s Tax Division has created an “Offshore Compliance Initiative” which is tasked with leading this effort.  According to the DOJ website, here are the latest statistics:

  • Since 2009, the Justice Department has criminally charged more than 30 banking professionals and 68 U.S. accountholders with violations arising from their offshore banking activities.
  • 54 U.S. taxpayers and four bankers and financial advisors have pleaded guilty, and five taxpayers have been convicted at trial.
  • One Swiss bank (UBS) entered into a deferred prosecution agreement, and a second Swiss bank (Wegelin) was indicted and pleaded guilty.
  • The Justice Department is currently investigating the Swiss-based activities of 14 financial institutions.
  • In addition to Switzerland, the Justice Department is actively investigating banks located in India, Luxembourg, Israel and the Caribbean.

Meanwhile, the IRS continues to offer amnesty (details available here) to those taxpayers who voluntarily disclose their offshore banking activities in a timely fashion — that is, before the U.S. government obtains information regarding their non-compliance.  Since 2009, more than 38,000 taxpayers have made voluntary disclosures to the IRS regarding undisclosed foreign bank accounts, generating over $5 billion in additional revenue to the U.S. Treasury.

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