On August 26, 2010, the Swiss government said it had reviewed approximately 4,450 UBS client accounts and that half of the data had already been handed over to the United States.
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On August 26, 2010, the Swiss government said it had reviewed approximately 4,450 UBS client accounts and that half of the data had already been handed over to the United States. 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 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. HSBC appears to be the next target of U.S. government in its fight against offshore tax evasion. On June 21, 2010, the Department of Justice issued letters to HSBC clients informing them that they are subject to a criminal investigation. On June 17, 2010, Swiss Parliament approved a Swiss-U.S. tax agreement that requires UBS AG to provide information to the IRS on 4,450 U.S. persons with undisclosed accounts at the Swiss bank. Lower house of Swiss parliament rejects UBS agreement with the IRS to disclosuse client data of 4,450 U.S. UBS account holders. The U.S. government expects to investigate thousands more cases of wealthy individuals dodging taxes through offshore bank accounts, in addition to the high profile and highly publicized case against UBS AG. It appears that in addition to probing the Swiss and Caribbean bank accounts, the U.S. may be looking at the Asian banks as well. Just as the April 15th deadline for filing income tax returns approached, the US government announced a bunch of new cases against the taxpayers who were hiding their assets in Swiss bank accounts. The parade of cases involved at least $145 million hidden in foreign bank accounts, according to the officials. Another UBS client pleads guilty to failure to file FBAR forms related to his Swiss account. U.S. prosecutors prepare a new wave of UBS-related tax evasion cases against individuals, and they do it just before the April 15 tax-filing deadline. On March 31, 2010, the U.S. and Switzerland signed a protocol to the 2009 agreement that called on Switzerland to provide administrative assistance under Article 26 (Exchange of information) of the Switzerland-U.S. income tax treaty regarding information on the U.S. clients of UBS (UBS Agreement). Although the terms of the protocol were not provided to the public, the Swiss Federal Council said that the revised UBS Agreement created the necessary legal basis for the Switzerland’s tax administration to issue final decisions on “cases regarding continued and serious tax evasion” and permitted Switzerland to comply with its obligations to the U.S. as required under international law. |
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