In today's world, big companies are often global companies -- which can create tax issues. Corporate tax avoidance is a concern of taxing authorities who want to make sure that businesses do not make strategic decisions on where to declare and keep income that deprives countries of needed revenue. Companies also need more certainty on tax laws across different jurisdictions, especially if there is a threat of retroactive penalties being imposed.

On December 10, 2015 the United States Department of Justice announced that it had reached a resolution with Bank Coop AG (Bank Coop) under the Swiss Bank Program. 

Seventy-two banks have reached an agreement with the IRS.

Offshore tax evasion has been and continues to be a top enforcement priority for the U.S. federal government.  On August 19, 2013 the United States Department of Justice (DOJ) and the Swiss Federal Government announced the creation of the Swiss Bank Program.