It was just announced that the Internal Revenue Service has
recommended that the UBS whistleblower, Bradley Birkenfeld, receive
over $100 million from the US government. Birkenfeld, a former
banker, provided confidential data on Americans who held overseas
accounts at UBS in 2007, which launched the Department of Justice
investigation of UBS.
The result was a massive enforcement action against offshore
account holders and the 2009, 2011, and 2012 Offshore Voluntary
Disclosure programs. Despite serving a 40-month prison term,
Birkenfeld is entitled to whistleblower compensation under a 2007
law. Birkenfeld's success in claiming this award should surely
make it easier for future whistleblowers to decide to come forward
with information. Few doubt that the era of foreign bank secrecy is
over, but does this award portend the beginning of the era of the
vigilante tax snitch?