Taxation: Wikileaks, Elmer, Bank Julius Baer and the IRS.

The announcement that about 2,000 people and companies are named in documents that Elmer handed to Julian Assange of Wikileaks yesterday is a cause of concern to many. He was careful not to identify which bank the information he handed over came from but, instead, to say that three major financial institutions were included.

He claims that politicians, entertainment figures and organised crime bosses are listed amongst others.

But the US Treasury will be more fired up, as they were with his previous release, over the prospect that details will emerge of US taxpayers who hold undeclared assets - and income - offshore.

Scott Michel, the senior partner of US law firm Caplin and Drysdale, says that the ramifications are potentially huge: "Public display of this data will definitely give tax authorities fodder to open new investigations. Since it is difficult for the IRS to find people who have failed to disclose foreign accounts, it will not ignore the names of such individuals when they are provided on a silver platter irrespective of whether the data was stolen by a disgruntled banker or released by WikiLeaks."

The US government, like most governments, has no problem with its own hypocrisy: while it chases Wikileaks over the release of government documents claiming they were obtained illegally, it has already demonstrated that it has no problem in using documents obtained in breach of the laws of other countries: the case of Guardian Bank in the Cayman Islands is a case in point.

The existence of the list may trigger an avalanche of disclosures by people and companies afraid they may be on the list: "If WikiLeaks releases the name of an account holder before he or she has initiated a voluntary disclosure, the protections afforded by the IRS voluntary disclosure policy do not apply and criminal prosecution is a serious risk," says Michel. Certainly, he advocates early disclosure by those who fear they may be about to be named.

Although Elmer worked for Bank Julius Baer in The Cayman Islands, he did not indicate that the information he was handing over was from that bank nor that jurisdiction. Indeed, he has been holed up in Mauritius for a while and that is, quietly, building an offshore sector with some serious information protection measures in place.

It is the very uncertainty over what may be in the documents - which Elmer himself implies may not be entirely accurate - that creates such a widespread ripple effect.

For more on this story, see our sister publication BankingInsuranceSecurities.Com