By Arden Dale A DOW JONES NEWSWIRES COLUMN Americans unnerved by an expanded tax evasion probe are stepping out of the shadows to tell the Internal Revenue Service about more overseas savings accounts they had used to hide money away. A year ago, a wave of such disclosures came mostly from account holders at Swiss banking giant UBS AG (UBS). Now, people who have banked at HSBC Holdings PLC (HBC) and Credit Suisse Group (CS), and in countries that range from Israel to Thailand are seeking help navigating an IRS program that offers some amnesty for voluntary disclosures, according to tax attorneys. As the UBS tax-evasion probe unfolded last year, the IRS offered a special deal on penalties through its voluntary disclosure program. The deal has expired, but the program itself remains open and can still mean more lenient treatment than if an account holder waits for authorites to find him. Scott Michel, an attorney at Caplin & Drysdale in Washington, D.C., said his firm has received calls from account holders at HSBC and Credit Suisse, "as well as at banks located outside of Switzerland, increasingly in Hong Kong, Singapore and Israel," and that it is guiding some of them to the IRS. The IRS program has been in place for fifty years. A special penalty deal last year attracted nearly 15,000 individuals, according to IRS officials. The agency declined to comment on how many people have entered the voluntary disclosure program since then, and on where new applicants hold accounts. Bryan C. Skarlatos, a partner at Kostelanetz & Fink, LLP, said his firm also is representing clients with Credit Suisse offshore accounts, and at banks in England, France, Germany, Italy, Greece, Mexico, Iran, Egypt, Hong Kong, Singapore, India and Thailand. Credit Suisse declined to comment. Since at least last month, the Justice Department has been contacting some HSBC overseas account holders and telling them they were under criminal investigation. Letters have gone out to clients with accounts in Singapore and India, according to Edward M. Robbins, Jr. a partner at Hochman, Salkin, Rettig, Toscher & Perez, a law firm in Beverly Hills, Calif. In some instances, Justice Department agents have gone to people's homes. The letters say the agency is looking into whether taxpayers may have violated federal criminal laws by failing to report they had a financial interest in, or signature authority over, a financial account located in a foreign country. HSBC declined to comment on the matter, but company spokeswoman Juanita Gutierrez said the company "does not condone tax evasion." The DOJ declined to comment. (Arden Dale is a Getting Personal columnist who writes about personal finance; she covers topics including tax and estate planning, retirement, investment strategies, and financial needs of small businesses. She can be reached at 212-416-2234 or by email at
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