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

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.