It appears that U.S. prosecutors are about to begin a new wave of UBS-related tax evasion cases against individuals, and they plan to do it just before the April 15 tax-filing deadline. The first case in the new round of prosecutions — apparently intended to create a splash of media attention before tax day — was filed on Tuesday in the U.S. District Court for the Southern District of Florida, where many of the prior UBS-related cases have been prosecuted. The sources, who declined to comment on the record, said additional cases coming within days will charge individuals with evading U.S. taxes by using accounts at the Swiss bank and will be prosecuted in New York City and elsewhere.
The government has secured eight guilty pleas so far from UBS clients since the bank admitted that it helped taxpayers avoid U.S. taxes. Last year, UBS paid the government $780 million and gave information about 250 accounts to the U.S. authorities. Also last year, UBS settled the government’s civil case against it and agreed to hand over 4,450 more client names, though that deal is tied up in legal wrangling in Switzerland.
The Internal Revenue Service and its lawyers want to make a “big splash” to remind people of their duty to report offshore income, one source said. The cases prosecuted so far involved UBS clients with accounts in the range of $10 million and less. It appears that the new cases would be within that range. On April 5, 201, IRS Commissioner Doug Shulman said the agency is still working through an additional 15,000 records it received from individuals who took part in an IRS amnesty program for offshore income that ended in October of 2009. The agency is looking for patterns in the records to identify other banks and advisers that helped wealthy individuals avoid taxes. That area will be “the next wave,” of the investigation, Shulman said, without naming other banks.
Former IRS Attorneys of Holtz, Slavett & Drabkin can assist you to address tax compliance issues related to offshore bank accounts. You can contact us at (310) 550-6200.
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