The US offered US taxpayers the opportunity to voluntarily disclose
offshore bank accounts as part of an amnesty program earlier this year.
The choice? Come forward now and escape criminal prosecution or take
your chances later.
It turns out that a number of US taxpayers didn't feel quite so lucky.
IRS Commish Doug Shulman has announced that more than 14,700 taxpayers
came forward under the voluntary disclosure program. The disclosures
were in the billions and covered accounts in 70 countries.
The number is higher than originally projected due to the numbers of
taxpayers who made disclosures in the run up to the deadline. The
deadline for disclosures had initially been September 23 but was
extended to October 15 after input from tax professionals who were still
fielding questions about the program from taxpayers.
UBS and the feds separately reached a settlement where UBS, in addition
to a significant fine, agreed to release the names of over 4,500 US
account holders at the bank. So far, only a handful of names has
actually been released: at least two of those account holders have been
sentenced to prison for their activities.
The remaining names will be disclosed over the next 10 months. Under the
agreement, UBS will release the names of those account holders where
there is a reasonable suspicion of "tax fraud or the like." Generally,
that includes high dollar accounts and accounts where there is a lot of
movement of assets or complicated schemes. There will be procedure for
appeals available in Switzerland.
ABC News is reporting that lawyers are already whining that their
clients were misled by UBS about the extent of the banking secrecy. I
suspect that means that lawsuits will be filed. That is, of course, how
we like to solve problems in the US. It is *always* someone else's
fault, right? If the lawyers are smart, any such suits would do well to
land in Switzerland and not in the US. Beyond the whole "juries likely
don't have sympathy for rich people who hide their money" issue,
lawsuits based on the misdeeds of plaintiffs are not usually successful.
Of course, that hasn't stopped people from trying before.
For now, it's a waiting game for UBS clients. The question is: do you
feel lucky. now?
Source: taxgirl.com