Within the United States, 38,000 U.S. citizens have voluntarily come forward to report to the Internal Revenue Service that they had undeclared offshore financial accounts. All U.S. citizens must declare any foreign accounts to the IRS and must pay all taxes that are due on those accounts, as well as on any income earned.  Those who have come forward have paid more than $5.5 billion in back taxes.

The second largest bank in Israel, Bank Leumi, faces millions of dollars in potential penalties as part of a probe into whether the bank helped U.S. investors hide money and avoid paying the full amount of income taxes due to the United States government.

If you have money offshore in a bank in Switzerland, Israel, the Caribbean, Singapore or other countries, your banker and bank may soon be under investigation, if they are not already. The U.S. government is cracking down on tax evasion and they are going after banks and financial professionals with the hope that criminal prosecutions will convince these institutions to turn over customer data. So far, the strategy seems to be working.

Many U.S. investors have placed their trust in Swiss banks and bankers to maintain the strict secrecy standards that helped the banking industry in Switzerland to grow.  In Switzerland, tax evasion is not a criminal act (although tax fraud and money laundering are illegal).  Furthermore, the law and longstanding traditions make it a crime for Swiss bankers to disclose client names.

US citizens living abroad likely want to have bank accounts in the country where they live. This is especially true if the ex-patriot is interested in doing business in his new home country or has married a foreign spouse.  Unfortunately, a law passed in 2010 to fight tax evasion is having an adverse impact on the lives of ex-patriots who simply want to be able to have normal banking and investment firm relationships where they live.