According to a report in the Swiss newspaper Tages-Anzeiger the Swiss are poised to send the names of thousands of potential tax evaders who have Swiss Bank accounts over to the IRS, and/or the Department of Justice. The data files are, according to the unconfirmed report, due to begin coming over later in October. The report goes on to speculate that the banks on the list include Credit Suisse, Julius Bär, Zürich Cantonal Bank, Basel Cantonal Bank and Wegelin. These names shouldn’t come as any great surprise because it appears that the IRS has been actively investigating them for some time.
Whether or not the report turns out to be true is unknown. However, if it is, it leaves very little time for U.S. persons who have offshore bank accounts at these Swiss banks to make a voluntary disclosure to avoid a criminal tax prosecution for FBAR violations, tax fraud, or other crimes.
U.S. persons who have offshore financial accounts are required to file report to the IRS on Form TD F 90-22.1, Report of Foreign Bank Account (FBAR) on an annual basis. Failure to do so can result in jail time, or ruinous civil penalties.