UBS Case End of Round 3


Round One: With the joint announcement of the IRS and the SFTA on November 15, 2010 (see article for links), the cases that almost brought down UBS AG and broke Swiss bank secrecy laws is nearing an end.

The case was initially filed as a criminal case resulting in UBS AG paying $780 M USD in penalties, turning over information on 400 account holders and the Justice Dept agreeing to a deferred prosecution agreement.

Round Two: The second phase was a civil John Doe Summons enforcement proceeding where the IRS asked for information on 50,000 account holders. A compromise was fashioned following an amendment to the U.S. – Swiss Tax Information Exchange Agreement, where information on 4,500 accounts was to be provided. The joint announcements today show that account data on 4,000 accounts has been provided and that there are 500 +/- in appeals status.

The 4,500 account holders are among those U.S. persons who did not take advantage of the Offshore Voluntary Disclosure Initiative offered by the IRS up to October 15, 2009. The traditional voluntary disclosure program is still open to those taxpayers who are eligible and wish to come clean.

Round 3: The point of this article is that the announcements are not the end of the process of the US to break bank secrecy laws and attack money launderers, terrorists and tax evaders, in fact it is just the beginning.

Please see full article below for more information.

LOADING PDF: If there are any problems, click here to download the file.

Written by:

Published In:


DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Sanford Millar, Law Offices of Sanford I. Millar | Attorney Advertising

Don't miss a thing! Build a custom news brief:

Read fresh new writing on compliance, cybersecurity, Dodd-Frank, whistleblowers, social media, hiring & firing, patent reform, the NLRB, Obamacare, the SEC…

…or whatever matters the most to you. Follow authors, firms, and topics on JD Supra.

Create your news brief now - it's free and easy »


Sanford Millar
Law Offices of Sanford I. Millar

Experience and Qualifications: Over 30 years of experience in domestic and international tax... View Profile »

Follow Law Offices of Sanford I. Millar:

Reporters on Deadline

All the intelligence you need, in one easy email:

Great! Your first step to building an email digest of JD Supra authors and topics. Log in with LinkedIn so we can start sending your digest...

Sign up for your custom alerts now, using LinkedIn ›

* With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name.