On July15, 2010, Switzerland’s Federal Administrative Court rejected a UBS account holder’s complaint that sought to prevent the release of her client information to the U.S. tax authorities. The verdict may not be appealed. The ruling, which was made public on July 19, 2010, said that the taxpayer’s account satisfied the requirements for a turn-over under the Switzerland-U.S. agreement signed in August 2009. Under that agreement, the Swiss authorities agreed to hand over the account information on 4,450 persons with undisclosed accounts at UBS. The court also noted that the Switzerland-U.S. agreement was binding as it was ratified by Swiss parliament on June 17, 2010.
The ruling is significant because it signals the likely end-game for UBS account holders with undisclosed accounts who had sought to prevent their account information from being delivered to the IRS.
Copyright (c) 2010 Igor S. Drabkin. All Rights Reserved.