The US government is putting pressure on Switzerland to end its tradition of "banking secrecy",…
ABA Conference with Government Officials
The ABA recently held a conference titled National Institute on Criminal Tax Fraud and Institute on Tax Controversy. I attended the conference where many tax attorneys and government officials discussed issues of interest.
Also discussed was the effect of streamlined program to channel most taxpayers into streamlined rather than OVDP. Government official John McDougal said that the average $10,000 payment in streamlined suggests that the program is working and that most practitioners are appropriately channeling the small non-willful clients. Statistics were announced that show 18,000 streamlined submissions in the last year compared with 1,800 new OVDP submissions.
Tax professionals analyzed the streamlined submission’s certification process and the potential problems, particularly criminal from improper certifications of non-willfulness. A senior Dept of Justice lawyer, Mark Daly, said that he has been looking at a lot of certifications recently and some have “patently ludicrous” narratives presented to support the non-willful certification. He said that they are checking against information from other sources.