"The documents concerned comprise e-mail correspondence, including attachments, with clients domiciled in the U.S., as well as internal e-mail correspondence, including attachments, about clients domiciled in the U.S. and the U.S. cross-border business in general during the period from June 2001 to March 2011."
Other banks that confirmed that they sent documents, including employee names, to the U.S. are the private-banking unit of HSBC Holdings, Julius Baer Group AG, Zuercher Kantonalbank and Basler Kantonalbank.
Technically, once the IRS has obtained your identity from these records, you do not qualify for voluntary disclosure.
The mere fact that the Service served a John Doe summons, made a treaty request or has taken similar action does not make every member of the Joe Doe class or group identified in the treaty request or other action ineligible to participate.
However, once the Service or the Department of Justice obtains information under a John Doe summons, treaty request or other similar action that provides evidence of a specific taxpayer's noncompliance with the tax laws or Title 31 reporting requirements, that particular taxpayer will become ineligible for OVDP and Criminal Investigation's Voluntary Disclosure Practice.
For this reason, a taxpayer concerned that a party subject to a John Doe summons, treaty request or similar action will provide information about him or her to the Service should apply to make a Voluntary Disclosure as soon as possible.
If you are a US Person Living in Canada and have Unreported Income From Swiss Banks, contact the Tax Lawyers at Marini & Associates, P.A. for a FREE Tax Consultation at www.TaxAid.us or www.TaxLaw.ms or Toll Free at 888-8TaxAid (888 882-9243).
Read more at: Tax Times blog