IRS Commissioner Doug Shulman stated that "...people hiding assets and income offshore will find themselves increasingly at risk due to our efforts in [combating international tax evasion]." In fact, in June of 2010, the IRS and Department of Justice got the Swiss parliament to make a deal that would corrode Swiss bank secrecy standards. The bullying power of the IRS was strong enough to convince Switzerland to change its laws to give out private bank information on 4,450 of UBS's American clients.
UBS (Union Bank of Switzerland) is Switzerland's largest bank. It has a worldwide reputation for privacy. It no longer deserves that reputation. It encouraged U.S. citizens to use off shore bank accounts as a form of legal tax planning. Now, those Americans are facing the consequences of that bad advice—the IRS is prosecuting them for using abusive tax shelters. And, UBS is now betraying its clients by claiming that it helped them to hide money from the IRS.
In a press release on February 8, 2011, Shulman stated: "Combating international tax evasion is a top priority for the IRS. We have additional cases and banks under review. The situation will get worse in the months ahead for those hiding assets and income offshore." The IRS and Department of Justice did not stop with UBS. They are also preparing to or have gone after other banks with offshore banking, including HSBC, Credit Suisse, and banks in Hong Kong, Singapore, and the Cayman Islands.
Last year, the time expired for Americans to voluntarily report their UBS accounts to avoid criminal charges. Consequently, these offshore abusive tax shelter cases involve overlapping criminal and civil tax issues. Few lawyers and firms have successfully defended multiple civil and criminal cases. We have. Contact Us.