• Home
  • Latest
  • Fortune 500
  • Finance
  • Tech
  • Leadership
  • Lifestyle
  • Rankings
  • Multimedia

Trendingnow

1

Ex-PepsiCo CEO Indra Nooyi worked from midnight until 5 a.m. as a receptionist to pay for her Yale degree—and she says ‘respect went up’ because of it

2

Shark Tank's Kevin O'Leary says if he were 25 today, he'd chase these two booming opportunities in the world of AI

3

China’s birth rate just hit its lowest point since 1949—and Trip.com cofounder James Liang thinks that’s a threat to innovation

1

Ex-PepsiCo CEO Indra Nooyi worked from midnight until 5 a.m. as a receptionist to pay for her Yale degree—and she says ‘respect went up’ because of it

2

Shark Tank's Kevin O'Leary says if he were 25 today, he'd chase these two booming opportunities in the world of AI

3

China’s birth rate just hit its lowest point since 1949—and Trip.com cofounder James Liang thinks that’s a threat to innovation

Got a Swiss bank account? Time to fess up.

By
Lynnley Browning
Lynnley Browning
Down Arrow Button Icon
By
Lynnley Browning
Lynnley Browning
Down Arrow Button Icon
May 30, 2013, 9:00 AM ET
Add Fortune on Google for similar content.

FORTUNE — Are you among the suspected tens of thousands of Americans with a secret Swiss bank account that you are still hiding from the Internal Revenue Service? If so, you are about to acquire a Matterhorn-sized headache.

Switzerland made a desperate decision on Wednesday to save its battered private banking sector by allowing Swiss banks to cooperate with a broad tax evasion probe by U.S. investigators. It is likely to unleash a flood of fresh disclosures to the IRS by American taxpayers, lawyers say.

Such disclosures could trigger hefty fines that can reach a multiple of what an account holds. To stand a chance of reducing those fines, Americans with hidden Swiss accounts “should run, not walk, to jump in line with an IRS voluntary disclosure in light of this move by the Swiss government,” says Josh Ungerman, a tax and estates lawyer in Dallas and a former IRS prosecutor.

Lawrence Horn, a tax and business crimes lawyer in Newark, N.J. and a former federal prosecutor, says he expects “at least 10,000” American taxpayers to come forward in the next 12 months or so.

The Swiss decision has two key points: Over the course of 12 months, banks will be allowed to turn over to American authorities general statistical data on their work with American clients. More significantly, the U.S. can seek concrete account details — with names of taxpayers — if the U.S. Senate gets its act together and passes a double-taxation treaty already green-lighted by Bern.

MORE: U.S. citizens ditch passports in record numbers

The latter all but guarantees that a client’s name will be disclosed. But so, possibly, does the former: The IRS already has a trove of information from previous disclosures, including names of bankers, and prosecutors are working with authorities in other tax haven countries, notably Liechtenstein, to scare up details on Swiss banks and their clients. Around a dozen banks have been ensnared in the U.S. investigation, including UBS (UBS), Credit Suisse (CS), HSBC’s Swiss arm, Julius Baer and two cantonal, or regional, banks.

Wednesday’s decision by Bern, a significant moment in the annals of Swiss secrecy and client confidentiality, awaits approval by Swiss parliament, where some factions appeared incensed by the appearance of caving in to U.S. demands. Martin Janssen, a leading Swiss finance professor at Zurich University, called the decision “blackmail by a large nation,” referring to U.S. threats to indict banks should Switzerland not agree to cooperate. Prosecutors indicted Wegelin, Switzerland’s oldest bank that once had Napoleon as a client, in 2012, and the bank pleaded guilty in January, effectively shutting its doors for good.

Still, under U.S. tax laws that make willful nondisclosure a felony, American taxpayers who are eventually outed to the IRS under the Swiss decision could face draconian fines, penalties, and criminal charges. More than five-dozen Americans have been charged in recent years for tax evasion through Swiss and other offshore banks. So it’s critical that Swiss bank account holders come forward to the IRS before the agency finds them. Unlike the U.S., Switzerland does not generally consider tax evasion to be a crime.

MORE: IRS scandal may unleash a flood of conservative donors

Last year, the IRS revived its Offshore Voluntary Disclosure Initiative, offering tax evaders terms that were less generous compared with those under two prior programs in 2009 and 2011. Under the reopened program, entrants must file original and amended tax returns, pay back-taxes and interest for up to eight years and pay accuracy-related or delinquency penalties. The penalties, as a percentage of assets, range from as low as 5% to as high as 27.5%, depending on the amount of assets they hold overseas. Taxpayers caught by the IRS before entering the program can face penalties equal to 50% of the highest value in their accounts for each year of violation, a calculus that can make fines outweigh assets.

Two prior disclosure initiatives, in 2009 and 2011, brought in tens of thousands of taxpayers and $4.4 billion, according to IRS data. In all, some 38,000 taxpayers have come forward and paid $5.5 billion. Others have tried a “quiet disclosure” — filing returns, paying taxes, and hoping the IRS doesn’t notice or levy fines. Horn says a subset of tax evaders “are people who are resistant and calculated, who think they’re different and will take the risk” of continuing to hide their accounts.

“When it comes to U.S. taxpayers and Swiss bank secrecy, Elvis has not only left the building, he is not coming back,” says Robert Katzberg, a white-collar criminal defense lawyer in New York with Swiss bank clients. “A shockingly large number of U.S. taxpayers with undisclosed accounts have failed to realize this, but maybe now they will.”

About the Author
By Lynnley Browning
See full bioRight Arrow Button Icon
Add Fortune on Google for similar content.

Latest in

Finance
Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam
By Fortune Editors
October 20, 2025
Finance
Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam
By Fortune Editors
October 20, 2025
Finance
Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam
By Fortune Editors
October 20, 2025
Finance
Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam
By Fortune Editors
October 20, 2025
Finance
Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam
By Fortune Editors
October 20, 2025
Finance
Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam
By Fortune Editors
October 20, 2025

Most Popular

Finance
Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam
By Fortune Editors
October 20, 2025
Finance
Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam
By Fortune Editors
October 20, 2025
Finance
Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam
By Fortune Editors
October 20, 2025
Finance
Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam
By Fortune Editors
October 20, 2025
Finance
Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam
By Fortune Editors
October 20, 2025
Finance
Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam
By Fortune Editors
October 20, 2025
Fortune Secondary Logo
Rankings
  • 100 Best Companies
  • Fortune 500
  • Global 500
  • Fortune 500 Europe
  • Most Powerful Women
  • World's Most Admired Companies
  • See All Rankings
  • Lists Calendar
Sections
  • Finance
  • Fortune Crypto
  • Features
  • Leadership
  • Health
  • Commentary
  • Success
  • Retail
  • Mpw
  • Tech
  • Lifestyle
  • CEO Initiative
  • Asia
  • Politics
  • Conferences
  • Europe
  • Newsletters
  • Personal Finance
  • Environment
  • Magazine
  • Education
Customer Support
  • Frequently Asked Questions
  • Customer Service Portal
  • Privacy Policy
  • Terms Of Use
  • Single Issues For Purchase
  • International Print
Commercial Services
  • Advertising
  • Fortune Brand Studio
  • Fortune Analytics
  • Fortune Conferences
  • Business Development
  • Group Subscriptions
About Us
  • About Us
  • Press Center
  • Work At Fortune
  • Terms And Conditions
  • Site Map
  • About Us
  • Press Center
  • Work At Fortune
  • Terms And Conditions
  • Site Map
  • Facebook icon
  • Twitter icon
  • LinkedIn icon
  • Instagram icon
  • Pinterest icon

Latest in

Current refi mortgage rates report for July 8, 2026
Personal FinanceReal Estate
Current refi mortgage rates report for July 8, 2026
By Glen Luke FlanaganJuly 8, 2026
42 minutes ago
Mortgage rates today, July 8, 2026
Personal Financemortgages
Mortgage rates today, July 8, 2026
By Glen Luke FlanaganJuly 8, 2026
42 minutes ago
Current ARM mortgage rates report for July 8, 2026
Personal FinanceReal Estate
Current ARM mortgage rates report for July 8, 2026
By Glen Luke FlanaganJuly 8, 2026
42 minutes ago
Multiple Nomagic robots working side by side, automating the packing of customer orders in e-commerce fulfillment.
AIRobots
Nomagic’s new AI lab headed by former Google DeepMind researcher claims success in early deployment of ‘AI brain’ for warehouse robots
By Jeremy KahnJuly 8, 2026
43 minutes ago
se
CommentaryVenture Capital
Physical AI’s $50 trillion opportunity requires long-term conviction, but the payoff is huge 
By Amit ChaturvedyJuly 8, 2026
43 minutes ago
Asia’s super-aging societies are sparking a boom in high-end longevity clinics—even if ‘public enthusiasm’ is outpacing the science
AsiaPersonal Health, Fitness, and Wellness
Asia’s super-aging societies are sparking a boom in high-end longevity clinics—even if ‘public enthusiasm’ is outpacing the science
By Angelica AngJuly 8, 2026
43 minutes ago

Most Popular

Ex-PepsiCo CEO Indra Nooyi worked from midnight until 5 a.m. as a receptionist to pay for her Yale degree—and she says ‘respect went up’ because of it
Success
Ex-PepsiCo CEO Indra Nooyi worked from midnight until 5 a.m. as a receptionist to pay for her Yale degree—and she says ‘respect went up’ because of it
By Preston ForeJuly 6, 2026
2 days ago
Shark Tank's Kevin O'Leary says if he were 25 today, he'd chase these two booming opportunities in the world of AI
AI
Shark Tank's Kevin O'Leary says if he were 25 today, he'd chase these two booming opportunities in the world of AI
By Marco Quiroz-GutierrezJuly 5, 2026
3 days ago
China’s birth rate just hit its lowest point since 1949—and Trip.com cofounder James Liang thinks that’s a threat to innovation
Asia
China’s birth rate just hit its lowest point since 1949—and Trip.com cofounder James Liang thinks that’s a threat to innovation
By Nicholas GordonJuly 7, 2026
1 day ago
Current price of oil as of July 7, 2026
Personal Finance
Current price of oil as of July 7, 2026
By Joseph HostetlerJuly 7, 2026
19 hours ago
Despite a $220 million net worth, Rafael Nadal says he won't retire because he hates waking up to no plans—so he's opened a chain of hotels instead
Success
Despite a $220 million net worth, Rafael Nadal says he won't retire because he hates waking up to no plans—so he's opened a chain of hotels instead
By Orianna Rosa RoyleJuly 7, 2026
1 day ago
Even as Elon Musk calls philanthropy ‘very hard,’ everyday Americans gave a record $617 billion—despite feeling the squeeze over the cost of living
Success
Even as Elon Musk calls philanthropy ‘very hard,’ everyday Americans gave a record $617 billion—despite feeling the squeeze over the cost of living
By Preston ForeJuly 4, 2026
4 days ago

© 2026 Fortune Media IP Limited. All Rights Reserved. Use of this site constitutes acceptance of our Terms of Use and Privacy Policy | CA Notice at Collection and Privacy Notice | Do Not Sell/Share My Personal Information
FORTUNE is a trademark of Fortune Media IP Limited, registered in the U.S. and other countries. FORTUNE may receive compensation for some links to products and services on this website. Offers may be subject to change without notice.