As a result of ongoing investigations into allegations of facilitating tax evasion, U.S. officials have extended an offer to 11 Swiss banks, including Credit Suisse, Julius Baer, HSBC Switzerland, and Basler Kantonalbank, to end the investigations in exchange for a fine to be paid by each bank and the disclosure of U.S. client data.
According to published reports, the proposed arrangement would require the Swiss banks to provide correspondence between the banks and their U.S. clients, including information from individual client phone calls and meetings, internal memorandums circulated by bank management to U.S. clients, and correspondence between the bank and third parties (such as independent wealth managers) regarding U.S. clients. The U.S. will apparently require each bank to disclose the names of the Swiss bankers involved, but the names of the U.S. clients will apparently be redacted from the information provided.
The offer follows the 2009 settlement with UBS, where the bank paid a substantial fine and agreed to provide certain U.S. client information to the U.S. authorities, and the 2011 Offshore Voluntary Disclosure Initiative.
U.S. taxpayers with non-U.S. financial accounts should contact their tax advisors regarding their income tax compliance and reporting requirements, including the requirement to file the FBAR form (Form TD F 90-22.1) and the new requirement to file Form 8938, Statement of Specified Foreign Financial Assets.