The I.R.S. did not respond to questions on whether it had told the Swiss government how many UBS account holders had come forward under the voluntary disclosure program.
It also included others who had reported themselves to the tax office under a voluntary disclosure initiative that allowed people to come forward and avoid steep penalties and criminal charges.
The Swiss cabinet said it might put the disclosure of the names up for approval before the Swiss Parliament — but only if it received detailed information from the Internal Revenue Service on how many UBS clients had come forward under a voluntary disclosure program that ended in November.
The Swiss tax authorities will not pass on any data to the U.S. Internal Revenue Service until the UBS agreement has been approved by Parliament, the government said, except where those concerned have given their consent to the data transfer, or have reported themselves to the I.R.S. under a voluntary disclosure program.
Under a voluntary disclosure policy the IRS updated in December, if the source of your income is legal and you turn yourself in before the government gets on to you, you'll almost certainly escape prosecution.
Notwithstanding that Sen. Levin envisions billions if not trillions of dollars hidden offshore, the fact is that most of the people who have come forward under the Voluntary Disclosure program, as noted earlier, are average citizens with accounts not in the millions of dollars, but in the hundreds of thousands.
The 800 individuals under investigation include some taxpayers who had previously been investigated and others who had reported themselves to the tax office under a voluntary disclosure initiative, as well as a large number of taxpayers who had not previously come forward.
Under the IRS' longstanding "voluntary disclosure" program, individuals who fess up and pay up before the IRS begins investigating or auditing them, are unlikely to be referred for criminal prosecution.
Officials also announced on Wednesday what they said was the final extension to a voluntary disclosure program under which prosecutors would agree not to bring criminal charges or file civil lawsuits against any Long Island Rail Road retirees who admitted they had been awarded Railroad Retirement Board disability benefits by making false statements and who agreed to give up certain benefits.
At the same time, Liechtenstein, Monaco and every other "tax haven" has agreed to greater transparency and information sharing with the U.S. The world of "secret" offshore banking is over, and many Americans with foreign accounts came clean under an IRS amnesty known as the Voluntary Disclosure Program, rather than face severe penalties and criminal prosecution.
