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.

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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.

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