The IRS's heated pursuit of individuals with offshore accounts is becoming more aggressive by the day. With tactics like John Doe Summonses, the feds took aim at Swiss banking secrecy and delivered a fatal blow. This war is hardly new.
In 2009, the feds brought UBS down with a deferred prosecution agreement and a $780 million fine. Since that victory, the IRS and DOJ have shown no sign of slowing down. With 120 prosecutions and nearly 40,000 Americans coming forward to confess, the IRS is gaining momentum.
The IRS isn't only after taxpayers who might attempt to evade their taxes but also those who are enabling them. Many foreign bankers and advisers have been prosecuted, with the names and addresses of their clients added to an ever-growing mountain of information.
With the FATCA, a pervasive U.S. law that requires foreign banks and financial institutions to report on Americans, 2014 is looking to be a rough year for offshore tax evaders. Some bankers will face personal exposure. It won't be long before virtually all nations adopt very broad disclosure policies.