Bloomberg reports that Swiss bank USB AG will pony up $780 million "to avoid U.S. prosecution and settle regulatory claims that it helped thousands of wealthy Americans use Swiss bank accounts to evade taxes."
Tom Herman, in his WSJ Tax Report column, noted recently that the Internal Revenue Service has "issued guidance" on whistleblower claims under a 2006 law. The statute doubles the rewards available to individuals who squeal on tax cheats.
You can see the IRS's announcement here. It includes links to Notice 2008-04, which describes relevant procedures, and Form 211, the "Application for Award for Original Information".
The new program allows bounties of between 15 and 30 percent of the extra that the IRS collects. The old regime limited payments to 15 percent or less.
Qui tam cases under the False Claims Act require a claimant to file a lawsuit under seal. The IRS program, by contrast, involves filing papers with the Whistleblower Office — a process that, at first blush, looks simpler and easier for the whistleblower but that now promises the same potential award levels.
The release helpfully ends with the note that "[a]wards will be subject to normal tax reporting and withholding requirements."
Let's see . . . 30 percent of $780 million equals how much?