‘Forceful Enough’

“The prospect of U.S. prosecution has been forceful enough to cause 43,000 taxpayers to self-report and pay nearly $6 billion in taxes and penalties,” Pierce said in an e-mailed statement. “More than 100 Swiss financial institutions have applied for a program where they fully disclose their illegal conduct, cooperate and pay steep penalties. That program will help the department root out tax evasion throughout the world.”

She also said the department has acknowledged that 14 Swiss banks are under investigation and “won’t hesitate to indict if and when circumstances merit.”

In addition, 106 Swiss banks are seeking non-prosecution agreements with the Justice Department.

Despite the committee’s criticisms, the offshore crackdown has made enormous strides against bank secrecy, according to tax attorney Charles Rettig of Hochman, Salkin, Rettig, Toscher & Perez PC in Beverly Hills, California. People inside and outside the U.S. seek advice on making voluntary disclosures.

“The majority of those people are told to come into compliance one way or another, and they follow that advice,” Rettig said. “You have to keep reminding them that the government’s out there.”

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