The Swiss Finance Ministry said it has released data on half of the 4,450 accounts it promised to IRS. “Based on information received to date and assurances by the Swiss government, we anticipate being in a position to withdraw the John Doe summons this fall,” IRS said in a statement. Read Article at reuters.com

UBS held a telephone conference today, June 15, 2010, to update practitioners on the status of the Swiss government's action on the treaty. The UBS representative explained that the government-to-government treaty requires parliamentary approval, and, at this point, both houses of parliament have approved a form of the deal. However, one house is calling for a referendum by the voters. If both houses cannot agree, a reconciliation counsel will be appointed in an effort to resolve the dispute.

Ultimately, the UBS representative expected a final decision by Parliament no later than June 18, 2010, which is the end of the parliamentary session.

From Reuters.com
See a timeline of major events at reuters.com

From Reuters.com
A Swiss tax deal with the United States, crucial to the future of Swiss bank UBS, moved closer to legislative sign-off on Tuesday after the lower house of parliament backed the deal. Read Article at reuters.com

From Reuters.com
Linda J. Osuna, IRS Special Agent in Charge of the Tampa Field Office, told Reuters the expected U.S. case against the foreign bank, which she declined to name, would be for "the same behavior that got UBS in trouble."
Read Article at reuters.com

The Justice Department announced on December 2, 2009, that it has filed papers seeking a federal court order authorizing the Internal Revenue Service to serve a "John Doe summons" on Ralph Janvey, the court-appointed receiver of the Stanford Group Company and related entities. The John Doe summons requires the receiver to provide documents identifying those U.S. taxpayers holding foreign accounts at or through Stanford Group Company, Stanford Trust Company Ltd., and Stanford International Bank during 2002-2009. (Excerpt from the press release).
» Read Full News Release

The Securities and Exchange Commission charged Robert Stanford in February of 2009 with operating a multi-billion dollar Ponzi scheme.
» View Our Offshore Voluntary Disclosure Information

The deadline has passed for the IRS offshore voluntary disclosure program. The program offered taxpayers with offshore accounts or entities the opportunity to come forward and avoid criminal prosecution and take advantage of reduced penalties. However, taxpayers who did not take advantage of the program may still make a voluntary disclosure in an effort to avoid criminal prosecution under the IRS' pre-existing voluntary disclosure policy.

From IRS News Release IR-2009-84, Sept. 21, 2009: The Internal Revenue Service announced a one-time extension of the deadline for special voluntary disclosures by taxpayers with unreported income from hidden offshore accounts.
These taxpayers now have until Oct. 15, 2009
» Read Full News Release

Contact Robert M. McCallum at 206-624-1040 with any questions.

Swiss Bank UBS to Release Account Information to IRS From IRS News Release IR-2009-75, Aug. 19, 2009: The Internal Revenue Service and the Department of Justice today announced the successful negotiation of an agreement that will result in the IRS receiving an unprecedented amount of information on United States holders of accounts at the Swiss bank UBS. As a result of this agreement, the IRS will receive substantially all of the accounts that it was interested in when it initiated the John Doe summons against UBS.
» Read Full News Release
» View Agreement Between the U.S. & Swiss Governments (120kb PDF download)
» View UBS AG's Settlement Agreement (PDF download)

Contact Robert M. McCallum at 206-624-1040 with any questions.

The Internal Revenue Service has unveiled a penalty framework which it will apply to voluntary disclosures of unreported offshore accounts and offshore entities. The penalty framework provides for reduced penalty rates and limits the number of years involved. Significantly, the penalty framework provides for partial relief from the devastating FBAR and information return penalties the IRS may otherwise impose. However, the reduced penalty framework is available only for a limited time.

IRS has issued substantial guidance regarding the Offshore Voluntary Disclosure Program. This information can be found on the IRS website HERE.

Contact Robert M. McCallum at 206-624-1040 with any questions.

According to a United States Department of Justice news release, UBS AG has entered into a deferred prosecution agreement on charges of conspiring to defraud the United States. As part of the agreement, UBS AG agreed to provide the identities and account information for certain United States customers. See link to news release immediately below:

February 18, 2009: View
July 1, 2008: View
June 30, 2008: View