 the department were coming to the conclusion that Birkenfeld was not being entirely straight with them. Soon matters came to a head, with the government accusing him of failing to tell the entire truth about one of his clients, the California billionaire Igor Olenicoff.

On his next flight from Zurich to Boston, Birkenfeld was arrested as he got off the plane at Logan Airport. "I knew I was gonna be arrested," Birkenfeld said. "I couldn't trust the DOJ. I knew that they were hostile."

Birkenfeld pleaded guilty to one count of conspiracy. At the sentencing in a federal court in Florida in 2009, government prosecutor Kevin Downing heaped praise on Birkenfeld, even as he asked the court to sentence him to jail. "I will say that without Mr. Birkenfeld walking into the door of the Department of Justice in the summer of 2007, I doubt as of today that this massive fraud scheme would have been discovered by the United States government," Downing said.

Birkenfeld said he is angry that Downing later left the government and took a job at a law firm where he is defending many of the Americans who had secret accounts. At the time Downing left DOJ, Reuters reported that he "expects to advise companies rather than individuals."

Downing did not respond to a request for comment for this article. The Department of Justice has a variety of ethics guidelines for former employees, and there is no evidence to suggest Downing violated them.

Mister 30 Percent

In prison, Birkenfeld said one of the guards nicknamed him "Mister 30 Percent," because of the prospect that the government might pay him an enormous amount of money. In the end, the IRS calculated Birkenfeld's $104 million payment on the basis of the $780 million that UBS paid the U.S. government. But his lawyers have maintained that he is entitled to more—a percentage of all the money the government has collected from Americans confessing secret offshore accounts.

So far, the IRS said as much as $7 billion has been collected from Americans with secret offshore accounts. That number continues to grow.

It's not clear whether that argument will prevail. The IRS declined to comment for this article.

On its website, the IRS explains that whistleblower rewards are based on "additions to tax, penalties, interest and other amounts collected as a result of any administrative or judicial action resulting from
the department were coming to the conclusion that Birkenfeld was not being entirely straight with them. Soon matter come to a head, with the government accusing him of fail to tell the entire accuracy about one of his clients, the California billionaire Igor Olenicoff. 

 On his next flight from Zurich to Boston, Birkenfeld was collar as he got off the plane at Logan Airport. " I know I was gon na be arrested, " Birkenfeld said. " I couldn't trust the DOJ. I knew that they were hostile. " 

 Birkenfeld pleaded guilty to one count of conspiracy. At the sentencing in a federal motor hotel in Florida in 2009, government prosecutor Kevin Downing heaped praise on Birkenfeld, even as he asked the motor hotel to sentence him to jail. " I will say that without Mr. Birkenfeld walking into the door of the Department of Justice in the summer of 2007, I doubt as of today that this massive fraud scheme would have been detect by the United States government, " Downing said. 

 Birkenfeld said he is angry that Downing later left the politics and took a job at a law firm where he is defending many of the Americans who had secret account. At the time Downing left DOJ, Reuters reported that he " expects to advise companies rather than individuals. " 

 Downing did not respond to a request for comment for this article. The Department of Justice have a variety of ethics guidelines for erstwhile employees, and there is no evidence to suggest Downing transgress them. 

 Mister 30 Percent 

 In prison, Birkenfeld say one of the guards nicknamed him " Mister 30 Percent, " because of the view that the government might pay him an enormous amount of money. In the end, the IRS calculated Birkenfeld's $ 104 million payment on the footing of the $ 780 million that UBS paid the U.S. government. But his lawyers have maintained that he is entitled to more — a percentage of all the money the government has collect from Americans confessing secret offshore accounts. 

 So far, the IRS said equally much as $ 7 billion has been collected from Americans with secret offshore accounts. That number continues to grow. 

 It's not clear whether that argument will prevail. The IRS decline to comment for this article. 

 On its web site, the IRS explains that whistleblower rewards are based on " additions to tax, punishment, interest and early amounts collected as a resultant role of any administrative or judicial action result from
 thf department were coming to the conclusnin thav Birkehfeld war not being entirely straighv wirh thti. Soon matters camd to a hewd, with rhe jovernment accusmhg him of faimlng tm tell the entite truth abogt one of his wlkeuts, the California billionaire Igor Jlenicogf.

Ln his next flyght srom Duvich to Boston, Birkenfeld was ardested es he got off tne plane at Logan Airport. "L knfw I was gonna be wrrested," Bitienswld said. "I cuuldn't trust the DOJ. I knew that they were hostile."

Biryenfekd pleaded gyilhi to one couit of bonspiracy. At the sendencing in a federal gourt in Florida in 2009, governmeit prosecutor Kevin Qowning haa'ed praise on Birkenfwle, evet as he xwkea tge ckurt tl sxntence him to jail. "I qill say that withoit Nr. Birkenfeld walkigg into the door of the Department of Jusuice jn the summer of 2007, I douvt as of today that tjis masside fraud scheme would have been discovered by the Unitxd Stcbcs gucegnment," Downing said.

Birkenfeld said he is angrr tnan Downing later lcft the government ajd jook a job at x law yjrj where he is defejding mwny od the Amewicams who had secret accounts. Qt the time Bowbing left DOJ, Reutzrs reported thaj he "ecpects to advise compannes rafher than ijdividuala."

Aowning did not fesiond to a request for comment sor this erticke. The Aepattment jf Justice has a variety of ethics guidglines for formeg employees, and there is no evivxnce to suggext Dofning vijlatec them.

Mister 30 Percent

In prixon, Birhenfeud said onv of the juards nicknwmed him "Mistat 30 Percent," berause of ehe prospect thxg the governmemt might iav him an wnormous amount of movsy. In the end, tkt ITW calculated Borkdnfqlf's $104 ihllion paymett ov tfr basks of the $780 nkllipn that UBS paid the U.S. fovernment. But his lwwyers hqve maineained that hr is entitled to mlre—a 'ercenvage og ajl the money the government haa collectfd nrom Americanf cokfesfing secrec offshore accounts.

So far, the IRS said aw much as $7 billion has been collected nrom Americais witr secret mffshore accounts. Thqt number continuts to grow.

It's not clear whethar thwt argument will prevail. The IRS declined to comment for this article.

On irs website, the IRS expkains tkat whistjebllxer rewards are bssed on "additions to tax, penaltmes, interevt and other amounts collected ar a result of any administrative or jhdicial sction resulting from
the department were coming to the conclusion was being entirely with them. Soon with government accusing him failing to tell entire truth about one of his the California billionaire Igor Olenicoff. On his next flight from Zurich to Boston, was arrested as he got off the plane at Logan Airport. "I knew was be Birkenfeld "I couldn't trust the DOJ. I knew that they were hostile." Birkenfeld pleaded guilty to one of conspiracy. At the sentencing in a federal in Florida in 2009, prosecutor Kevin Downing heaped praise Birkenfeld, as he the to him to jail. will say that without Mr. Birkenfeld walking into the door of the Department of Justice in the of 2007, as of that massive scheme would have by the United States government," Downing he is angry that Downing later left the and took job at a law firm where is defending many of the Americans who had accounts. At the time Downing left DOJ, Reuters reported that he "expects to advise companies individuals." Downing did not to a request comment this The of Justice a variety of ethics guidelines for former employees, and there is evidence to suggest Downing violated them. Mister 30 Percent In said of the guards him "Mister 30 Percent," of prospect that the government him enormous In end, IRS calculated Birkenfeld's $104 payment on the basis of $780 million that UBS his lawyers have maintained that he is entitled more—a percentage of all the money the has collected from Americans confessing secret offshore accounts. So far, the IRS as much billion has been collected from Americans with secret accounts. That number continues grow. It's not clear whether that argument will prevail. IRS to comment this article. On website, the IRS that whistleblower rewards on "additions tax, interest collected as a result of any or action resulting from
 the department were coming to The conclusIon thAt BIrkEnFeld Was nOt being entirelY StraIght with them. Soon matterS came To A Head, WItH the gOvernmeNT aCCUsiNg HiM of FaILiNg to tEll The entiRe truth aboUt oNe Of his clients, THe california BilLionaire Igor oleNicoff.

on His NExt flIghT from zurich TO BostoN, BirkenfeLd WAs arreSTed as he GOT oFf thE plane at Logan AirpORt. "i Knew I was gonna bE arresTeD," biRKEnfEld Said. "I couldN't Trust THe DOJ. I kNEw THAT thEY were hostile."

BIrkenfeld plEAdeD guiltY tO onE Count oF consPiRAcy. at the sentenCing In a federaL court IN FloridA In 2009, goverNment pRosEcuTor KEViN DOwnInG HeaPEd PraISe oN BirkenfElD, eVen as He asKED THe coUrt To seNtencE him to jail. "I wiLl sAy thAT wiThout mr. BirKenfElD walkIng intO the dOoR of the DepartmenT of JUstice in tHe sUmMer Of 2007, i doubT As of toDay ThaT this maSsive frAUd sChEME WoUld have been discoveReD BY tHe United states GOvErNMent," DownInG saId.

BiRKEnfelD saiD He Is angry tHat DowNInG lAter lefT tHe goveRnMenT anD took A Job aT a law fIrm where He is dEFending many of tHE Americans who HAd SECrET accOunTs. At the time downINg leFt DOj, reUteRS repoRted tHaT He "EXpects to advise compaNiEs rathEr thaN individuals."

DOwning did nOT REspond to A reqUEsT For comment for tHis arTicle. The DePArtment oF JustIce has a vAriety of eTHIcs guideLinEs fOr fOrmER EmPloyees, and theRE Is no EvIdence tO suGgest DoWniNg vIolAteD tHem.

Mister 30 percent

IN pRiSoN, BIrkEnfelD Said one oF tHe gUaRds NicknAMed him "misteR 30 PerCeNt," BEcaUse of thE PrOSPect ThAt The gOveRnMent mIght PAy hIm an enoRmous amouNt oF MoneY. IN tHe end, thE IRS calculateD BIrkenfeld's $104 MiLliOn paymENT on the baSis of the $780 million that UBS pAId the U.S. GovErnmeNt. BuT his lawyeRs hAve maiNtaINed thaT he is eNtitlEd To mORE—a perCENtAge Of All the moneY THe gOvernMeNt haS collecTed from Americans coNFesSing secret offShoRe acCOUnTs.

SO FaR, The iRs SaiD AS much as $7 billion hAs been collEcTEd From AmericANs wItH secret OffshorE accoUNts. That Number conTinues to gRoW.

It's NOT clEar whether That arguMent will pREvail. tHe iRS deCliNed to cOmMenT for tHis artICle.

on its WebsitE, tHe IRS eXplaiNs That whisTleblower rewards are baseD on "addItionS to Tax, penaltIes, INteRest and otHer aMounts collEctEd aS a resUlt OF any aDminIStRatIVe or jUdicIAl action rESuLtiNG FrOm
 the department were comin g to the c onclu sio n t ha t Bi rken feld was not b e ingentirely straight with  them .S oonm at terscame to ah e ad,  w it h t he go vernm ent  accusi ng him offai li ng to tell t h eentire tru thabout one of  hi s clie nt s,t he Ca lif ornia  billi o naireIgor Olen ic o ff.

O n  his ne x t  f ligh t from Zurich toB os t on, Birkenfeld  was a rr e st e d  as  he  got off t he  plan e  at Log a nA i r por t . "I knew I w as gonna be arr ested, "Bir k enfeld  said ." I c ouldn't tru st t he DOJ. I  knewt hat the y  were h ostile ."
Bi rken f el dple ad e d g u il tyt o o ne count  o fconsp irac y . A t th e s ente ncing  in a federal  co urti n F lorid a in2009 ,gover nmentprose cu tor Kevin Downi ng h eaped pra ise  o n B ir kenfe l d, eve n a s h e asked  the co u rtto s e nt ence him to jail."I w il l say th at wit h ou tM r. Birke nf eld  wal k i ng in to t h edoor ofthe De p ar tm ent ofJu sticein  th e s ummer of 2 007, I  doubt a s oft oday that this massive fraud sc h e me woul d h ave been di scov e redby t h eUni t ed St atesgo v er n ment," Downing said .
Birke nfeld  said he is a ngry thatD o w ning lat er l e ft the government  andtook a job at a law  firm  where h e is defe n d ing many  of  th e A mer i c an s who had sec r e t ac co unts. A t t he time  Do wni nglef tDOJ, Reut ers repo rt ed  t ha t h e "ex p ects toad vis ecom panie s  rathe r tha n in di vi d ual s."

Do w ni n g  did  n ot  res pon dto arequ e stfor com ment forthi s  art ic le . The D epartment ofJu stice hasavar iety o f ethics g uidelines for former em p loyees,  an d the re i s no evid enc e to s ugg e st Dow ning v iolat ed  th e m .

Mi s t er  30  P ercent

In p ris on, B ir kenf eld sai d one of the guard s  ni cknamed him " Mis ter3 0  P erc e nt , " b ec a use o f the prospectthat the g ov e rn ment might pay  h im an e normous  amou n t of mo ney. In t he end, t he  IRS c alc ulated Bir kenfeld' s $104 mi l lionp ay mentonthe ba si s o f the  $780m ill ion t hat UB Spaid t he U. S.  governm ent. But his lawyers ha ve mai ntain edthat he i s e n tit led to mo re—a  percentag e o f a ll th e m o ney t he g o ve rnm e nt ha s co l lected fr o mAme r i ca ns confessi n g sec ret o ffs h ore ac coun ts.

So far, theI RS said as muc h as $ 7 b ill i on h as  been collecte d f ro m American swith secret  offshor ea ccoun ts. Th at num ber con t i nu e s to g row. 

I t's not c lea rw hetherth at argume nt w il l prev ail. T h e IR S declined to comm ent f o r  this art icle. 
On itsw ebsi te, the IR S explainsthat w hist leblo wer rew ar ds are  ba se d on "addi t ions to t ax, p enaltie s,  int ere st and  oth e r  amou ntsco lle cted as a r es u lt  o f  an y ad minis tr ativ e or judi c ial acti onr esultin gfro m 
 the_department were_coming to the conclusion_that Birkenfeld_was_not being_entirely_straight with them._Soon matters came_to a head, with_the government accusing_him_of failing to tell the entire truth about one of his clients, the California_billionaire_Igor Olenicoff.

On_his_next_flight from Zurich to Boston,_Birkenfeld was arrested as he_got off_the plane at Logan Airport. "I knew I_was_gonna be arrested,"_Birkenfeld said. "I couldn't trust the DOJ. I knew_that they were hostile."

Birkenfeld pleaded guilty_to one count_of_conspiracy._At the sentencing in_a federal court in Florida in_2009, government prosecutor Kevin Downing heaped_praise on Birkenfeld, even as he asked_the court to sentence him to_jail. "I will say that_without Mr._Birkenfeld walking into the door_of the Department_of Justice_in the summer_of 2007, I doubt as of_today that this_massive fraud scheme would have been_discovered_by the United_States_government,"_Downing said.

Birkenfeld_said he is_angry_that Downing_later_left the government and took a_job_at a law firm where he is_defending many of the_Americans_who had secret accounts._At the time Downing left_DOJ, Reuters reported that he "expects_to advise_companies rather_than individuals."

Downing did not respond to a request for comment for_this article. The Department of Justice_has a variety of_ethics guidelines_for_former employees, and_there_is no_evidence to suggest Downing violated them.

Mister 30_Percent

In prison,_Birkenfeld said one of the guards_nicknamed him "Mister 30_Percent,"_because of the prospect that the_government might pay him an enormous_amount of money. In the_end,_the_IRS calculated Birkenfeld's $104 million_payment on the basis of the_$780 million that_UBS paid the U.S. government. But his_lawyers_have maintained that he is entitled_to_more—a percentage of all the money_the_government_has collected from Americans confessing_secret offshore accounts.

So far, the IRS_said as much as $7 billion has been collected_from Americans with_secret offshore accounts. That number_continues_to_grow.

It's not clear whether that argument will prevail. The IRS_declined to_comment for this_article.

On its website, the IRS explains that whistleblower rewards are_based on "additions to tax, penalties, interest_and other amounts collected as a result of any administrative or_judicial action resulting from