Finance committee   on such a taxpayer—but under American law, these penalties theoretically were so high that American taxpayers were discouraged from coming forward. So a small group of practitioners—I was part of this group—approached the IRS in 2008 and urged them to adopt a settlement initiative that would

Finance committee  Well, that's a good question. In fact, a number of practitioners have been talking to the IRS about the possibility of adopting a second settlement initiative. I actually received an e-mail from a colleague today that there was some rumour that it might even be announced

Finance committee  I've always thought that tax enforcement pays for itself and then some. Obviously, the government has many budgetary needs. What happened in the United States 20 years ago or so is the IRS became a punching bag politically and took some unfair criticism. And the IRS retrenched

Finance committee  I would say that relying on voluntary disclosure without some fairly strong enforcement at the same time would only give you half a loaf; that if voluntary disclosure is accompanied by aggressive enforcement, if the CRA has resources such as were given to the IRS to go after UBS

Finance committee  There's a debate in the United States over just how successful this IRS program was. I happen to be of the view that, notwithstanding some of the procedural and bureaucratic difficulties, from a macro perspective it was enormously successful. Over 30 years of practice, before

Finance committee   in the accounts over the previous six years. The demographics and the amounts varied. I would say that our clients who have been put into this program have paid anywhere from 30% to the high 40%s, or maybe even 50%, of their foreign account back to the IRS for global peace. I think it's one

Finance committee  , and they have to pay taxes on their capital gains. The U.S. bank will give the client a 1099 every year, a form that says that this is how much money you have to put on your tax return. That's reported independently to the IRS. A bank in Panama or Switzerland or Hong Kong is not going

Finance committee  It has not yet taken effect. Significant portions of it don't come into effect until 2013. And financial institutions like HSBC and others are struggling with a fairly significant compliance burden to implement it. The IRS has issued one set of guidance on implementation