by Christina Przybilla

“If you are a U.S. citizen or resident alien, the rules for filing income, estate, and gift tax returns and paying estimated tax are generally the same whether you are in the United States or abroad. You are subject to tax on worldwide income from all sources and must report all taxable income and pay taxes according to the Internal Revenue Code.” www. irs.gov

Remember when Leonardo DiCaprio playing Jordan Belfort aka “The Wolf of Wallstreet” walked into the office of a Swiss bank and asked the banker character Jean-Jacques Saurel about their bank secret, and Saurel jokingly mentioned “American plans to invade Switzerland in a couple of months?” In retrospective, the joke about an American invasion and “tanks rolling down the Rue de La Croix” (with a French accent) came almost ironically at time when Swiss banks were dealing with a different form of American invasion, that of their banking system: the very same bank secret that had allowed Jordan Belfort to hide his illegally earned money by using someone else’ identity was now under attack from the State Department because too many American ex-patriots had not been paying their taxes as required per the American tax code.

It would only be a year after the release of the movie, in 2014, that the managers of the Swiss banks pleaded guilty to aiding American citizens evade taxes in the famous case of the American Justice Department versus Swiss banks. A few months later, in March 2015, the American Justice Department imposed a whooping 1.3 billion on a total of 80 Swiss banks as a penalty for their admitted aiding of tax evasion. Since that day, the relationship between Swiss banks and American citizens, criminal or not, has never been the same. Swiss banks were forced into total compliance.

Because of this “clerical invasion,” American citizens were from hereon forced not only to declare their American citizenship to the Swiss banks, but also, to sign a W9. It is of little consequence what kind of a background the American citizens came from. Honorable or not – Swiss banks could no longer discriminate that way. If you have an American passport, it will take some persuasion skills, and a lot of paperwork, and probably also a lot more money than the average citizen has, to convince a Swiss bank to let you continue or start business with them. Also, all the information that you give them will be disclosed to the IRS. So, no more bad guys hiding cash in La Suisse, please. It just doesn’t work that way anymore. While it is still possible that wealthy Americans will have an easier time opening or keeping accounts in La bella Svizzera, it is practically impossible for these wealthy people to hide their dollars from the IRS. Their funds will be declared. So why bring them there?

Another consequence of these newly imposed rules between US clients and Swiss banks, is one that few people know about. Many Americans, especially those who are of average income, were forced to close their accounts simply because the Swiss banks, who view their new relationship with the IRS as one with a “police state” (source undisclosed), did not want to deal with the administrative effort it would take to manage their new and/or old clients’ business with the IRS. Old clients who had their accounts at these banks for years were turned away and forced to close their accounts. Where were these people, many of whom had been living in Switzerland for more than half their lives, supposed to put their money? Under their pillows?? A flurry of citizenship renunciations occurred, and it is certainly no coincidence that the fee to renounce one’s American passport, which cost US$450 until 2010, was raised to US$2350 in 2014. The State Department knew that people, who had spent most of their lives abroad, weren’t going to be able to hold on to their citizenships if life had been made so difficult for them, and so the State Department made a nice little chunk of money on the side by raising the fee for these passport renunciations.

Enough about that now. Let’s return to our original topic: bad guys hiding money in Swiss banks. It is not the aim here to provide an answer to the question where bad guys should put their money nowadays. That’s the writer’s job to do the reseearch. But do it , please!

I do hope, however, after the above deliberations, that writers in Hollywood who want to be taken seriously not only be local producers but by citizens of this world, will stop having their villains hide their money in Der Schweiz, and start taking their villains to some other country where they can have them stash their cash in an offshore account that is not under such strict scrutiny as the banks in Switzerland.

Or, if they want to create something more original and stop using the old cliché of the villain hiding money in Switzerland, it could be a refreshing plot twist to look at some of these American ex-patriots who have been living abroad all these years and suddenly changed their citizenships. Was it really just manageability that drew them to renounce the little blue booklet or were they actually accomplices to the crime?