DOJ Tax Division Moving Forward With Swiss Bank Letters of Intent

For over 50 years, Bloomberg Tax’s renowned flagship daily news service, Daily Tax Report® has helped leading practitioners and policymakers stay on the cutting edge of taxation and...

The Department of Justice Tax Division “is moving forward” with the 106 letters of intent the department has received from institutions that want to participate in its program for Swiss banks to share information about U.S.-owned accounts and pay fines to avoid prosecution, DOJ's top tax official said.
DOJ Tax Division Assistant Attorney General Kathryn Keneally told reporters at a briefing April 9 not to “expect 106 prosecution agreements.” The government needs to determine whether those who submitted letters of intent are all Swiss banks and eligible for the program (18 DTR K-1, 1/28/14). The division has “committed significant resources to the 106 letters, set deadlines and is working toward those deadlines,” she said.
When asked about Swiss bankers being caught between U.S. prosecutions and Swiss bank privacy laws, Keneally said: “Bankers who see themselves as having criminal liability are coming forward to reduce that liability. Each individual needs to come forward. Issues with Swiss law need to be addressed in Switzerland.”

Request Daily Tax Report