Amnesty By Any Other Name: Government Enforcement Drive Against Foreign Bank Account Holders Highlights Little Known IRS Voluntary Disclosure Policy
The recent, public hearings conducted by Senator Levin’s Sub-Committee on offshore tax havens and their bank secrecy laws and the well-publicized parallel IRS summons enforcement efforts to compel Swiss banking giant UBS to provide the names and account records of the 53,000 U.S. taxpayers for whom UBS has admitted to maintaining undisclosed foreign bank accounts, have put the spotlight on a massive non-compliance problem affecting those taxpayers and perhaps the same number or more who have accounts at other banks in Switzerland or in other tax haven countries.