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those individuals have, "maybe the least important, frankly," he added. "They may not mind avoiding tax but what they really want to avoid is being kidnapped and held for ransom," the expert said.
Panama Papers is a story about global risk and global transparency and the notion that there's eventually going to be a leak, said Matthews, who added, "Heaven help us when it comes from a government source in the age of FATCA and the common reporting standard." Matthews said that the current leak will probably end up benefiting enforcement "because it worries people." Individuals with hidden entities and accounts who were assured by advisers in Switzerland, Panama, or Hong Kong that their arrangements are perfectly safe have got to be thinking "That's for the birds," Matthews said.
How Will the Data Be Used?
Responding to a question about whether the Panama Papers has revealed new jurisdictions worth investigating at the Tax Bridge to Practice session of the American Bar Association Section of Taxation meeting in Washington May 5, Caroline Ciraolo, acting assistant attorney general in the DOJ's Tax Division, said, "We don't target jurisdictions, we follow the money." Ciraolo said that she was dispelling the rumors that specific jurisdictions such as Singapore or Hong Kong will be targeted next. (Prior coverage
government is working on those cases, she added.
Ciraolo said that the information for new cases is coming from the 80 Swiss banks that signed
non-prosecution agreements with the DOJ, including detailed U.S.-related account information,
individual facilitator information, and leaver lists for transfers of money out of the banks. The
government has also been getting information from treaty requests, cooperation by those under
investigation, and whistleblowers, she said, adding that Switzerland has been responding to the
treaty requests quickly and that "whistleblowers are coming from every corner." (Prior coverage .)
"Anyone who has an undeclared account now, who thinks it's going to continue to remain concealed, they are misreading the room," Ciraolo said.
Skarlatos said he expected the ICIJ information to be entered into a database along with all of the information the government has been gathering for the last several years through initiatives like the DOJ's Swiss bank program and the IRS's offshore voluntary disclosure program. Some individuals will have direct action taken against them, but the data will probably confirm a lot of what the IRS and DOJ already know, he said.
Song said he'd like to see the government use the data to initiate investigations. "Until the Department of Justice starts prosecuting these individuals from abroad, people will try to keep themselves buried," he said. "I hope the Criminal Investigation division looks at the list and compares it with what they have now, including those in [the] OVDP. People who haven't come forward should be held accountable."
Song said he also hopes it will aid in the effort to establish worldwide information exchange. "Greed is global," he said. "It's hurting everyone, and jurisdictions need to work together on something concrete to get this kind of information out."
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.) A tremendous amount of information regarding undeclared accounts has been pouring in to the DOJ for a while now, and the
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