I’ve posted the indictments against two Swiss bankers, issued yesterday in the USA.
Note (para 13) they’re charged with fraud, not tax offences. Why? Note this commentary on the US – Swiss extradition treaty:
The Switzerland Treaty is distinguished primarily for granting a Requested State discretion to deny extradition for violations of ``currency policy, trade policy, or economic policy,'' or acts ``intended exclusively to reduce taxes or duties'' (art. 3(3)). According to the Secretary of State's Letter of Submittal, this provision was included in the treaty at Swiss behest because Swiss law for the most part prohibits extradition for purely fiscal or tax offenses.\2\ The Letter of Submittal also states, in what appears to be an expression of hope, that ``[T]his provision would not be used to shield from extradition underlying criminal conduct, such as fraud, embezzlement, or falsification of public documents, if that conduct is otherwise extraditable.'' No similar statement appears in the treaty itself.
Looks like the US is taking no chances on tax charges: fraud it is.
I think the Swiss know they’d better make it work.