The IRS is searching thousands of secret records obtained from 80 Swiss banks to determine whether 30,000 US Taxpayers who entered the Streamlined Offshore Voluntary Disclosure Program were truthful. The “SOVDP” was for US taxpayers who claimed they had innocent reasons for failing to disclose off-shore holdings and paid minimal or no penalties (US residents paid a 5% penalty, overseas residents paid none). The IRS is now “taking all that data and scrubbing it for leads” which includes Swiss bank account information and recordings of phone calls with US clients. The IRS (Nanette Davis, trial attorney in US DOJ Tax Division) stated: (for some taxpayers) we could “indict this case tomorrow”.
See article, America’s Offshore Tax Cheats are Feeling the Heat Once Again, Bloomberg.com