Swiss Federal Administrative Court Denies IRS Request for Bank Records from Credit Suisse

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Friday, June 1, 2012
Author: 
Bruce Zagaris
Volume: 
28
Issue: 
6
Abstract: 
              On April 5, 2012, the Swiss Federal Administrative Court affirmed the appeal of one of Credit Suisse’s (CS) depositors, who brought an action to prevent the disclosure of his bank account data to the Internal Revenue Service (IRS).  The Court concluded that the U.S. request was made for purposes of tax evasion whereas the 1996 Swiss-U.S. income tax treaty allows assistance only for cases of tax fraud.[1] [1]               Swiss Federal Administrative Court, Credit Suisse:  IRS Request for Administrative Assistance Not Sufficient for the Disclosure of Client Data, April 10, 2012.