On January 9, 2012 the IRS reopened its Offshore Voluntary Disclosure Program (OVDP) to encourage U.S. taxpayers with undisclosed offshore accounts to come into compliance. The renewal of the program was in response to continuing interest from U.S. taxpayers after the 2009 and 2011 programs ended.

A grand jury returned indictments against three client advisers, Michael Berlinka, Urs Frei, and Roger Keller, who were employed under Swiss private bank Wegelin and Co. These advisers were charged of conspiring with their U.S. clients to assist in maintaining undisclosed offshore accounts from the IRS. According to the indictment, the three allegedly instructed prospective U.S. clients that their account information would be safe at Wegelin because of the bank’s small size and because it had no branches outside Switzerland.

Credit Suisse, Switzerland's second-largest bank, has begun notifying their U.S. clients with undisclosed offshore accounts that the Bank intends to turn-over client data to the Internal Revenue Service (IRS). Credit Suisse’s decision to hand-over client information was in response to a formal request by the IRS issued on November 2, 2011. This development may pressure the Swiss Government into finalizing a settlement with the U.S. in hopes of absolving all tax evasion allegations before U.S. agencies begin to formally request the information.

The Swiss Government recently proposed a multibillion-dollar settlement to U.S. authorities, likely to reach $10 billion or more. This settlement was proposed to remedy pending investigations and allegations regarding the potential involvement of Swiss banks in encouraging U.S. clients to commit tax evasion through undisclosed offshore accounts. The settlement is expected to cover all Swiss Banks, approximately 355 banks, including Credit Suisse.

European banks are ready to pay billions to the United States, as well as disclose U.S. clients’ names to the Internal Revenue Service (IRS) and the Department of Justice (DOJ). Switzerland has been known as one of the largest tax havens in the world and wishes to continue its long-practiced tradition of tax secrecy and has allegedly agreed to divulge information requested by U.S. agencies, including U.S. taxpayer information.