In the Federal Tax Crimes blog from Jack Townsend, we find an interesting point of view from Mark Matthews regarding the US Tax Program for Swiss banks. Mark Matthews is a lawyer at Caplin & Drysdale and a former IRS Deputy Commissioner. He seems to believe that the United States will probably not launch a tax regularization program in other countries than Switzerland. The US Department of Justice (DoJ) discovered that interacting with around 100 Swiss bank on the agreed US Tax Program requires more resources than anticipated. For that reason, M. Matthews ‘does not expect another version of the program in the future’. However, Jack Townsend thinks that this does not exclude that banks elsewhere might still get prosecuted and pay penalties as there ‘are way more bad foreign banks than can be prosecuted or even investigated civilly without massive resources’.

If there will be no other tax regularization program, this would leave Switzerland at an unequal treatment level.

The DOJ and IRS are particularly interested in the so-called leaver lists which identifies US-related clients that left a Swiss bank and went to another bank (Swiss or otherwise). These moves are subject to extra scrutiny from US instances.