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Credit Suisse’s Impact on Its U.S. Clients

Robert Horwitz and Steven WalkerAugust 11, 2014

In the government’s criminal investigation and charging of Credit Suisse AG with helping U.S. taxpayers evade taxes, the IRS used a new and little-known provision of the code, section 6201(a)(4), to ensure that the Swiss bank paid $666.5 million in restitution to the Service. This article examines the effect of the IRS’s restitution-based assessment on the bank’s U.S. clients.