Skip to Main Content

Charles Ruchelman Comments on Israeli Bank Disclosures

February 3, 2014

Nationwide media from the Jewish community have quoted Charles M. Ruchelman concerning the tax implications for U.S. citizens with unreported Israeli, Swiss, or other foreign bank accounts.  The U.S. Department of Justice and the Internal Revenue Service are requiring foreign banks, including Israeli and Swiss banks, to disclose information on their U.S. account holders.  For additional coverage, please see the links below.

Heritage Florida Jewish News
Tax Attorney CPA Blog
The Isaac Brock Society
Greenback Expat Tax Services
BDO Seidman's Silobreaker
The American Israelite
The Times of Israel
Jewish News

Excerpt taken from the article.

According to Charles M. Ruchelman, a member of the Washington, D.C. law firm of Caplin & Drysdale, some Israeli banks are already notifying U.S. account holders that they may be disclosing the relationship between the Israeli banks and their U.S. owners to the U.S. Department of Justice, which could result in fines—or even prosecution—for Israeli account holders who didn't inform the U.S. of the funds they have abroad.

"Israel wants to stay on the good side of the U.S. and to be a friend and an ally, so the banks are going to cooperate with the Internal Revenue Service and the U.S. government," Caplin & Drysdale's Ruchelman told

"[Americans with Israeli bank accounts] really need to talk to an attorney," Ruchelman said. "There is a cost to that, but doing so will be getting criminal exposure off the table so you can sleep at night."

Ruchelman said part of the reason for OVDP is to give individuals who really did not know about the law a chance to make good, and to get people back into compliance and back into the system. He explained that the U.S. is losing millions of dollars per tax year, which is multiplied exponentially over decades. He added that when FATCA goes into effect, there would no longer be a chance to plead innocent or ignorant.

Ruchelman explained, "Whether you are intentionally hiding it or not, the information will be sent to the IRS. … The IRS voluntary disclosure program … could change at any moment. … U.S. taxpayers should move quickly."



About Caplin & Drysdale
Celebrating our 55th Anniversary in 2019, Caplin & Drysdale continues to be a leading provider of legal services to corporations, individuals, and nonprofits throughout the United States and around the world. We are also privileged to serve as legal advisors to accounting firms, financial institutions, law firms, and other professional services organizations.

The firm's reputation over the years has earned us the trust and respect of clients, industry peers, and government agencies. Moreover, clients rely on our broad knowledge of the law and our keen insights into their business concerns and personal interests. Our lawyers' strong tactical and problem-solving skills -- combined with substantial experience handling a variety of complex, high stakes, matters in a boutique environment -- make us one the nation's most distinctive law firms.

With offices in New York City and Washington, D.C., Caplin & Drysdale's core practice areas include:
For more information, please visit us at
Washington, DC Office:
One Thomas Circle NW
Suite 1100
Washington, DC 20005
New York, NY Office:
600 Lexington Avenue
21st Floor
New York, NY 10022


This communication does not provide legal advice, nor does it create an attorney-client relationship with you or any other reader. If you require legal guidance in any specific situation, you should engage a qualified lawyer for that purpose. Prior results do not guarantee a similar outcome.

Attorney Advertising
It is possible that under the laws, rules, or regulations of certain jurisdictions, this may be construed as an advertisement or solicitation.
©2021 Caplin & Drysdale, Chartered
All Rights Reserved.

Related Professionals

Related Practice Area(s)