Nanette Davis, senior litigation counsel in the Tax Division said on December 10, 2015, that just because the Swiss entity of a multinational banking group received a non-prosecution agreement (NPA) through the DoJ’s Swiss bank US Tax Program does not mean that the other related entities are cleared with the US tax authorities.

A Swiss entity’s NPA does not give a pass to a related offshore entity in a different jurisdiction such as Hong Kong. The US Department of Justice is looking closely at the institutions and they already identified of some based on already opened grand jury investigations.

For further information visit Tax Notes‘ website and read the discussion of Caplin & Drysdale’s Scott D. Michel with Nanette Davis.