Academic journal article Journal of Accountancy

UBS Targets Come into Focus

Academic journal article Journal of Accountancy

UBS Targets Come into Focus

Article excerpt

The IRS has released the selection criteria for identifying holders of accounts with Swiss bank UBS under a U.S. settlement agreement with the Swiss government negotiated in August. Under the agreement, UBS will turn over information concerning approximately 4,450 accounts for investigation. IRS Commissioner Doug Shulman also announced that about 14,700 taxpayers had come forward to disclose offshore assets under a reduced penalty program, nearly twice as many as Shulman had estimated on Oct. 15, when the program ended.

The settlement agreement represented a compromise between the two governments over a contested "John Doe" summons in U.S. v. UBS AG, a case filed in the U.S. District Court for the Southern District of Florida. Generally, the selection criteria cover U.S.-domiciled UBS clients who directly or beneficially owned undisclosed custody accounts or banking deposit accounts exceeding 1 million Swiss francs (currency converter at tinyurl.com/ yaq79ug) at any time during 2001 through 2008 and about whom the U.S. government has a reasonable suspicion of tax fraud. Any U.S. persons (regardless of domicile) who beneficially owned offshore company accounts of any size during those years and whom the U. …

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