You can plan on the Internal Revenue Service continuing in its efforts to locate offshore account information. As an example, Switzerland recently announced its plan for disclosure of account information from HSBC Holdings to the IRS. HSBC is a private Swiss bank.
The Swiss announcement was to alert HSBC account holders of the plans to release this information. This would also give such account holders the ability to lodge an appeal to object to having such information shared with the IRS. With the notification, HSBC account holders have 30 days to appeal.
The IRS asked the Swiss government for assistance in locating information regarding the HSBC accounts in April. The IRS is looking for information regarding "U.S. beneficial owners" from 2002 until 2014. In particular, the IRS is looking for withdrawal of funds by account holders for personal use in violation of corporate governance. The agency is also seeking information regarding accounts over $50,000 where tax form discrepancies exist.
A spokesperson for HSBC stated the bank has provided files relating to former clients to the Swiss Federal Tax Administration (SFTA). The Swiss government may then provide "part or all of this information" to the U.S. The U.S. Department of Justice also is investigating the HSBC Swiss unit regarding efforts to help U.S. citizens evade paying taxes.
Lawsuits concerning offshore compliance may continue indefinitely. The punishment for noncompliance includes wage garnishment, seizure of assets and jail time. As the issues are extremely complex, you will require attorneys who understand the new IRS offshore regulations and who will fight to protect your rights.