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US 'Near To Deal' With Swiss Banks

by Mike Godfrey,, Washington

22 December 2011

Eleven Swiss banks are reportedly being offered a deal by the United States government, under which they would not be prosecuted if they were to disclose full details of their offshore business with US taxpayers.

It is expected that the deal being offered to the banks would follow the lines of the agreement which was reached early in 2009 between the Swiss bank, UBS, and the Internal Revenue Service (IRS), and that was confirmed by Switzerland’s Federal Supreme Court in July this year.

Under that deal, to avoid an indictment from the US Department of Justice, UBS agreed to pay USD780m in profits restitution, unpaid tax and penalties, while also transferring information regarding accounts of 4,450 US clients, who appeared to have committed tax fraud within the meaning of the Swiss-US double taxation agreement.

It is reported that the agreement the US is proposing to the eleven Swiss banks would entail full disclosure through the Swiss government to the IRS of their relationships with US clients, although their names will supposedly be able to be edited out. This would include funds that were transferred through the banks to third parties, while the banks would also be required to provide copies of correspondence between all parties.

It is unknown how close such a deal with the Swiss banks may be, but full details are expected early next year.

A comprehensive report in our Intelligence Report series, examining in depth the situation of offshore transparency and secrecy in a number of the most prominent jurisdictions, is available in the Lowtax Library at and a description of the report can be seen at
TAGS: compliance | tax | offshore confidentiality | tax compliance | tax avoidance | law | banking | Internal Revenue Service (IRS) | enforcement | tax authority | offshore | Switzerland | United States | penalties

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