We have previously posted news about more foreign banks reaching non-prosecution agreements with the Department of Justice, resulting in the turn over of U.S. account holders’ information to the U.S. authorities. In fact, the list of the banks on the IRS list of the financial institutions which had either reached an agreement with the DOJ, or which are under the DOJ investigation, now includes 27 names.
The list of the cooperating banks and financial institutions is going to grow. As an indication of how foreign financial institutions cooperate with the DOJ, please take a look at the attached letter, which we just received on behalf of one of our clients. It notifies us that the Liechtenstein Tax Administration issued a Final Order, granting administrative assistance and sharing of the documents with the U.S. Department of Justice.
Recent developments show that the IRS and Department of Justice will get more and more information from foreign banks and tax authorities. about U.S. taxpayers, resulting in the increased rate of criminal tax investigations and civil tax audits.
For questions related to U.S. compliance with foreign bank and asset requirements, please feel free to contact our Former IRS Attorneys at (310) 550-6200.
