The Tax Division of the Department of Justice and the IRS is increasing its scrutiny of offshore tax evasion with fourteen active federal grand jury investigations related to foreign banking institutions to identify and reveal American depositors. It is pursuing criminal investigations of scores of Swiss banks and also banks in Israel, Lichtenstein, Luxemburg, Barbados, Hong Kong, Singapore and others. Bank Leumi recently entered into a deferred prosecution agreement with the DOJ, paying $270 million and the bank agreed to identify numerous account holders in the U.S. to the I.R.S.. B.S.I, a Swiss bank paid $211 million and also turned over U.S. account holders.
The law requires that U.S. citizens report moneys in foreign accounts. Failure to report foreign accounts means filing a false tax return which may have criminal penalties.
The IRS whistleblower statute allows individuals with “specific and credible” information about tax evasion exceeding $2 million to collect a percentage of what the government recovers. The IRS program protects against disclosure of the whistleblower’s identity.