More than 6 million Americans live abroad and have an annual tax filing obligation with the IRS for either the US Individual Income Tax Return 1040 or FinCEN form 114 Report of Foreign Bank and Financial Accounts (FBAR).

John Doe summonses were issued at the end of 2014 on eight entities to produce records that will assist the IRS in identifying U.S. taxpayers who, from 2005 through 2013, used Sovereign’s services to establish, maintain, operate or control of any foreign financial account or other assets; any foreign corporation, company, trust, foundation or other legal entity; or any foreign or domestic financial account in the name of such foreign entity.

On the heels of the 100,000 names that were leaked from HSBC, there are 4,183 clients that are United States citizens. With this list the Department of Justice could cross-match these names to the results of the John Doe Summons issued in December 2014(see John Does Order) to determine a list of United States taxpayers that may be evading tax.

The Department of Justice Tax Division has been investigating HSBC in Switzerland since 2010. With the recent Swiss Leaks (team of journalists from 45 countries) that unearthed secret bank accounts maintained for criminals, traffickers, tax dodgers, politicians and celebrities, the Swiss government took action by raiding the Geneva office.

The Tax Division of the Department of Justice is prosecuting U.S. taxpayers that fail to voluntarily come forward and take advantage of programs like OVDP and Streamline Filing.

The article below brings reality to several myths floating around about FATCA. It highlights something very important to those individuals dealing with banks requesting a W-8 series or W-9 series form to be filled out by the taxpayer.

Foreign corporations, partnerships and trusts can take advantage of the protections of the Offshore Voluntary Disclosure Program. In doing so, we walk through an exercise in Ethics that most second or third year law students study: conflict of interest.

Italy and Switzerland came to an agreement on February 23rd, 2015 which effectively resolved the dispute on how to treat Italian citizens’ undeclared funds in Swiss bank accounts.

Commerzbank, Germany’s second largest bank, has agreed to pay the United States Government and New York State $1.45 billion for its role in money laundering schemes.