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.