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.

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

The United States government has been pressing UBS AG, one of the Switzerland’s largest banks, to release the names of a reported 52,000 wealthy Americans with accounts at the bank. Federal authorities suspect that some U.S. taxpayers may be using accounts at UBS to evade taxes. A civil case brought by the United States against [...]