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.

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.

Los Angeles Tax Attorneys at Holtz, Slavett & Drabkin represent numerous taxpayers in the IRS Offshore Voluntary Disclosure Program.  After the initial information is submitted to the IRS Criminal Investigation Division, a letter is sent from IRS CID stating that the taxpayer has been preliminarily accepted.  The letter further advises that the case will be forwarded for [...]

IRS Extends Deadline for Offshore Accounts Amnesty Program until October 15, 2009

UBS Offshore Account FBAR Update

IRS extends due date for filing some FBARs

The IRS issued a new notice, Notice 2009-62, 2009-35 IRB, which extends the due date for filing Form TD F 90-22.1 (Report of Foreign Bank and Financial Accounts (FBAR)) in certain cases.
The extension applies only to the following individuals:
(i) persons with signature authority over, but no financial interest in, a foreign financial account, and
(ii) persons with a financial interest in, or signature authority over, a foreign commingled fund.