Offshore accounts, and the bankers who manage them, have increasingly been targeted by the U.S. government in its tax evasion enforcement. This can be seen in a criminal tax case which has recently been brought against a Swiss banker.
Recently, the U.S. government has been stepping up its enforcement efforts against the use of hidden offshore accounts to commit tax evasion. As part of this enforcement, the government will sometimes conduct criminal prosecutions against the banks or bankers that it believes provided these hidden accounts to taxpayers. Such a case has recently arisen in Virginia.
We have discussed in the past how the IRS has begun to develop new methods to detect offshore bank accounts used by taxpayers. A recent federal case brought in Miami demonstrates a couple of potential new tactics the U.S. government may be using to pursue offshore accounts-related tax evasion.