The United States Department of Justice has opened a new front on its war against allegedly fraudulent tax shelters. On November 12, 2008, the United States indicted a senior executive at UBS AG for tax evasion. The indictment accuses the executive, Raoul Weil, of participating in a criminal tax evasion scheme involving other UBS executives, employees, and private bankers, as well as approximately 20,000 American clients. According to the indictment, Weil and other UBS executives, employees, and private bankers set up offshore accounts to hide approximately $20 billion in client assets and the income derived from those assets from the IRS. Weil allegedly characterized this branch of UBS’s business as “‘toxic waste’ because they [UBS] knew that it was not being conducted in a manner that complied with United States law….”

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