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?