The IRS Grills Taxpayers on Offshore Accounts

In 2009, as U.S. prosecutors were bearing down on Swiss bank UBS (UBS) to disclose the names of tax cheats, thousands of wealthy Americans decided it was best to avoid prosecution and come clean with the Internal Revenue Service. Under a limited amnesty program, they disclosed their secret offshore accounts and paid the taxes they owed, along with the reduced penalties that were part of the deal. They also agreed to turn over records and cooperate with the IRS.

Now, IRS agents and federal prosecutors are going back to some of those same people to milk them for more information on the bankers and advisers who helped them hide their money. So far, more than 200 offshore-bank clients have been questioned in what lawyers call a crackdown of unprecedented scope. The questions that taxpayers answered helped form the basis of an indictment of four Europe-based bankers at Credit Suisse (CS) in February, and a U.S. civil action against HSBC (HBC), according to people familiar with the matter. "This is the biggest tax investigation ever in the country, both in terms of the numbers of people and the money involved," says Robert S. Fink of Kostelanetz & Fink in New York, a tax lawyer for 43 years. "They are looking at what I call the enablers." Fink represents nearly 40 people contacted by investigators. "HSBC does not condone tax evasion. It fully supports U.S. efforts to promote appropriate payment of taxes," says HSBC spokeswoman Juanita Gutierrez.