UBS to Release Additional 4,500 U.S. Accounts

Due to the terms of its agreement made last year with the Internal Revenue Service and the Department of Justice, UBS is poised to release the bank account records of an additional 4,500 U.S. account holders.

"In three weeks, most of the remaining 4,500 accounts will be turned over to U.S. authorities," said Jim Mastracchio, a partner with Caplin & Drysdale. The Swiss government recently decided against a public referendum, which could have delayed the release of this material.

"This means there will be no further delay in the release of this information. Time is short for those who want to make a voluntary disclosure to the IRS," Mastracchio added.

Last March, the IRS announced a settlement program for offshore account holders who voluntarily disclosed the existence of foreign bank accounts and agreed to pay the back taxes. That program, which ended in October, had defined civil penalties and no criminal prosecution risk.

"The long standing policy of the IRS has been to allow taxpayers to voluntarily correct their tax returns and pay the outstanding tax liabilities without risk of criminal prosecution," Mastracchio said. "While the penalties that may apply to post-settlement disclosures will be based on a case by case basis, we expect the voluntary disclosure policy to apply to the remaining 4,500 account holders."

In the past few weeks, UBS account holders who are trying to make post-settlement voluntary disclosures have experienced delays in gaining clearance, Mastracchio noted.

To discuss the voluntary disclosure policy or other tax enforcement matters, please contact Jim Mastracchio directly at (202) 862-8859 or email: jnm@capdale.com.

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