The New US Department of Justice/Swiss Voluntary Disclosure Program: Know Your Options

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The U.S. Department of Justice, in its August 29, 2013 agreement with Switzerland, released a first of its kind Voluntary Disclosure Program (the “New Program”) for eligible Swiss Banks to come forward and resolve their status with regard to the DOJ’s ongoing tax enforcement investigations of Swiss banks. This program will review the Program and discuss the options a Swiss Bank has to navigate the Program. Panelists will answer the following questions:

• Background: Why was this program developed?
• Who is excluded from program and who is included in program?
• What are the options for Swiss Banks?
• How does a Swiss Bank decide whether to participate in program or not?
• What are the uncertainties in definitions and scope of program
• What Needs to be done in Switzerland?
• What Needs to be done in the US?

Educational Objectives:
• Identify the basic elements of the voluntary disclosure program; 
• Determine the appropriate liabilities involved in the program; 
• Locate the key relevant documents outlining the program and its functions; 
• Correctly determine the program categories of affected financial institutions; and 
• Determine the appropriate filing requirements for entities affected by the program.



Alan Winston Granwell is an international tax of counsel resident in DLA Piper's Washington, DC office. Mr. Granwell’s practice encompasses representing multinational corporations on cross-border planning, to include acquisitions, dispositions and business restructurings, IP migrations, services arrangements, repatriation planning, international insurance, international transportation, cross-border leasing, transfer pricing and the use of bilateral tax treaties. He also advises high-net-worth individuals on cross-border tax planning and structuring.

Recently, Mr. Granwell has become active in advising investors from emerging countries engaged in cross-border transactions involving the United States and Europe and in advising financial institutions and their clients on international tax enforcement initiatives, with special emphasis on the Foreign Account Tax Compliance Act.

From 1981 through 1984, Mr. Granwell was the International Tax Counsel and Director, Office of International Tax Affairs at the US Department of the Treasury. In that capacity, Mr. Granwell was the senior international tax advisor at the Treasury Department and was responsible for advising the Assistant Secretary for Tax Policy on legislation, regulations and administrative matters involving international taxation and directing the US tax treaty program.

Mr. Granwell also conducts an active administrative practice, regularly representing clients before the Internal Revenue Service and the US Treasury Department (including negotiating advance pricing agreements, conducting competent authority proceedings, advising taxpayers on voluntary disclosures, assisting clients in obtaining regulatory changes and tax rulings and advising clients on tax legislation matters). Mr. Granwell has written numerous articles and has been a frequent lecturer on international tax matters globally.


William Sharp has handled a multitude of international tax planning and international tax controversy cases during his thirty year career. Before starting a boutique international tax practice, SharpPartners P.A., Mr. Sharp served as a partner with Trenam, Kemker, Scharf, Barkin, Frye, O’Neill and Mullis, P.A., where he led the firm’s international practice group. Mr. Sharp has served as lead counsel with respect to United States Tax Court, Internal Revenue Service appeals and examination cases, and he also has served as lead counsel and co-counsel on a multitude of Internal Revenue Service voluntary disclosure cases. Mr. Sharp maintains significant contacts with other major international tax law firms located within the U.S. as well as abroad, and Mr. Sharp maintains ongoing contacts with senior members of the National Office of the Internal Revenue Service, as well as with regional and field Internal Revenue Service offices.

Mr. Sharp has served as an adjunct professor at the Stetson University School of Law and a lecturer at the University of South Florida Executive MBA program. Mr. Sharp is a frequent speaker on international tax and business law matters, and also has been quoted in the Wall Street Journal, the New York Times, the Washington Post, Reuters, USA Today and other media on international tax topics.

Mr. Sharp has been a member of the Society of International Business Fellows since 1985, and previously served as Chairman (2001). Mr. Sharp is a member of the Board of Advisors of The Carter Center, Atlanta, Georgia. Mr. Sharp is a frequent speaker on international tax and business law matters.


Bruce Zagaris is a partner with Berliner, Corcoran & Rowe LLP in Washington, DC.  Hehas a B.A., J.D., and LL.M. from The George Washington University. His B.A. included a major in international affairs with a specialty in Latin American Affairs. After serving as a law clerk for the U.S. District Court for the Southern District of West Virginia (1972-73), Mr. Zagaris was an Assistant Attorney General for the State of Idaho (1973-74). Mr. Zagaris received graduate legal diplomas from Stockholm University, Sweden (1975) and from the Free University, Brussels (1976). While in Scandinavia, Mr. Zagaris did research as a result of Swedish and Finnish government sponsored scholarships. His research resulted in three articles that were published and are noted below.

During his two years in Europe, in 1974-76, Mr. Zagaris worked for the Nordic Law Consultants and served as a UN consultant to the Mano River Union, a customs union in West Africa. At the Free University's Program on International Legal Cooperation (PILC), Mr. Zagaris took international criminal law from Bart deSchutter. In 1976-77, Mr. Zagaris was in private practice with Glad, Tuttle & White in San Francisco. In 1977-78, he was a lecturer at the Faculty of Law, University of the West Indies, Barbados, teaching comparative law, public international law, and international tax law.

Mr. Zagaris was an Adjunct Professor for six years at the Washington College of Law, American University in Washington, and at the Fordham University Law School in New York, where he taught international business criminal law. He has also been an Adjunct Professor at John Marshall College in Chicago and the University of Montana School of Law.

Mr. Zagaris has served as a consultant, counsel and lobbyist for fourteen governments on various subjects.