SUMMARY: Recently there has been a great deal of activity in the United States and the European Union ("EU") concerning possible tax evasion or avoidance through secret offshore accounts. This has included litigation by the U.S. government in Florida concerning Americans with secret bank accounts at UBS in Switzerland. There are a reported 52,000 Americans with such UBS accounts. The issue is by no means restricted to UBS or Switzerland. Congress and the Obama administration have also shown a great deal of interest in ending noncompliance by Americans with offshore accounts and ending other perceived international tax abuses.

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