Mark Matthews Comments on U.S.-Swiss Program to Combat Tax Evasion

Mark E. Matthews spoke with Tax Notes concerning the Justice Department's announcement on August 29 that the United States and Switzerland have outlined a program to be implemented by the two nations to combat tax evasion by U.S. citizens with undisclosed finances in Swiss banks.  For the complete article, please visit Tax Notes' website (subscription required).

Excerpt taken from the article "U.S. and Switzerland Outline New Program to Combat Tax Evasion" by Andrew Velarde for Tax Notes

Mark E. Matthews of Caplin & Drysdale, former chief of the IRS Criminal Investigation division, noted the significance of the program. "Across the board, it looks like a step-up in enforcement and aggressiveness in what the U.S. and the IRS have been doing for the last four or five years," he said.

But Matthews said the program offered some reprieve for many Swiss banks. "This is going to be an attractive opportunity for any of the financial institutions other than the 14 banks [already under investigation] in Switzerland who are worried about their status under U.S. law. It's going to be expensive, particularly for those banks that persisted with . . . helping customers move from one bank to another," Matthews said, adding, "But, ironically, it gives them a bit of an out." Matthews explained that if the banks get their customers to make voluntary disclosures to the U.S. before the program goes into effect, "it looks as though they will get a discount on the penalty."