The Internal Revenue Service’s Senior Counsel in charge of the Offshore Program recently announced that more guidance on duel citizenship and how it will affect undisclosed offshore account holders will be released as supplemental information to the current 2012 IRS Voluntary Disclosure Program. This information will provide US taxpayers, who may hold a duel citizenship, with undisclosed offshore accounts a better understanding of their tax liability.

Switzerland recently authorized its banks to hand over the names of professional employees, external wealth mangers, lawyers and trustees who have helped U.S. taxpayers commit tax evasion. Moreover, the banks are authorized to release email traffic in connection with U.S. taxpayers who are suspected of maintaining an undisclosed offshore account. The release of such information will likely contribute to establishing cases against those U.S. taxpayers currently under investigation. While U.S. client data is not being released at this moment, the employee information will help the IRS in its investigations into both foreign banks and U.S. taxpayers with undisclosed offshore accounts.

Recently, it has been reported that U.S. taxpayers who have maintained undisclosed offshore bank accounts with Credit Suisse are beginning to receive letters from the bank concerning their undisclosed offshore accounts. According to World Radio Switzerland, the letters from Credit Suisse date back to February 2, 2012 and advise their U.S. clients to hire a tax controversy lawyer and enter into the IRS’s 2012 Voluntary Disclosure Program in order to avoid potential criminal investigation.

Wegelin & Co. officials, who facing criminal charges of helping Americans evade taxes, failed to appear at a Manhattan court hearing on February 11, 2012. Wegelin is the first overseas bank to be indicted by the U.S. for aiding tax fraud, federal prosecutors say. These new developments will likely result in the turn over of more U.S. client data to U.S. authorities.

The IRS reported that eight banks, including the Swiss bank Basler Kantonalbank, turned over U.S. client data on taxpayers suspected of tax evasion on January 30, 2012. This does not put an end to the negotiations between the U.S. and Switzerland; three more banks are still expected to turn over client data and a total of 11 banks, also including Basler Kantonalbank, are expected to pay heavy fines.