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Of Swiss Banks, Privilege, and Facta

September 15, 2014
Michigan Business Law Journal

Originally published in the Michigan Business Law Journal:

The Spring 2014 Tax Matters column focused on Internal Revenue Service (IRS) and U.S. Department of Justice enforcement practices. In particular, it emphasized their collective focus of international tax enforcement as the top priority—think offshore financial accounts. On May 19, 2014, perhaps the most tangible signs of the fruits of their priorities played out in a federal courthouse in Virginia. In Criminal Case No. 1:14-cr-188, Swiss banking giant, Credit Suisse (parent company) pled guilty to one count of conspiring to aid tax evasion in a scheme that “spanned decades.” 

Specifically, Credit Suisse AG pled guilty to one count of violation of IRC 7206(2), the aiding, assisting, procuring, counseling, and advising of the preparation and presentation of false income tax returns to the IRS in violation of 18 USC 371.

The plea agreement provides, in part, for restitution of $666.5 million plus a $2 billion fine, as well as an independent monitor for two years. 

Read the article in its entirety: Of Swiss Banks, Privilege, and Facta

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