Tax Law

UBS Probe Puts 300 Americans, Maybe Many More, in IRS Sights

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As a major Swiss bank is squeezed between the secrecy law of its own country and a threatened U.S. prosecution for helping American citizens hide their assets, the government reportedly is getting ready to launch criminal tax evasion cases against 300 American clients of UBS.

But the roster of tax evasion cases could grow much larger if UBS bows to U.S. demands that it reveal the names of as many as 19,000 more Americans believed to have secret accounts at the Swiss bank, reports the New York Times.

Although it is not illegal for U.S. citizens to hold offshore accounts if they report and pay tax on their income, prosecutors suspect that UBS helped Americans hide $20 billion and thus avoid paying some $300 million a year in taxes between 2002 and 2007.

“The bank is in a round of talks with the Justice Department to avert a possible felony indictment by admitting to criminal conduct and paying a penalty in the range of $1.2 billion,” reports the Wall Street Journal (sub. req.), relying on unnamed sources.

A federal court in Florida issued a civil summons last year ordering UBS to reveal the names of all U.S. clients, but the bank has not yet complied, the Wall Street Journal notes.

However, “while the bank has not provided any names, it has in recent months submitted—under a subpoena from the Manhattan district attorney, Robert M. Morgenthau—related records detailing wire transfers originating from the United States to same-name accounts in Zurich,” the Times writes.

Earlier ABAJournal.com coverage:

After Indictment of UBS Executive, Swiss Bank’s US Clients Seek IRS Deals

New IRS Rules Target Secret Offshore Bank Accounts

Revised Reporting Law Could Mean Big Penalties for U.S. Clients of UBS

IRS Isn’t Just Pursuing UBS Clients; Auditors to Look at Other Foreign Banks

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