The United States announced a new program in cooperation with the Swiss government that allows Swiss banks not currently under criminal investigation to be eligible for non-prosecution agreements in exchange for their cooperation in investigating offshore tax evasion schemes. The program will require participating banks to pay penalties, disclose cross-border activities, provide detailed information on accounts in which US taxpayers have an interest, cooperate in treaty requests for account information, provide detailed information on transferor banks that have transferred funds into secret accounts, and to close accounts of taxpayers that have failed to comply with reporting obligations. The program is designed to help the government prosecute taxpayers that have moved funds to different banks to enhance the secrecy of the accounts. The program is also intended to help Swiss banks resolve their liabilities with the US government for failing to disclose secret accounts where tax evasion is suspected.
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