Tuesday, April 14, 2009

UBS Yacht Broker Client Pleads Guilty -

One of UBS's american clients, a Florida yacht broker, pleaded guilty to filing a false tax return today. According to government sources, the false tax return was filed on October 18, 2008, and failed to report his interest in a UBS account in Switzerland. He also failed to report the income he earned on his UBS bank accounts. The account was owned through a panamanian corporation. 
 
That means it took the government less than six-months to investigate and prosecute the case -

It also appears that this case may be related to the criminal complaint filed a couple of weeks ago against the Florida accounant (see prior posts) many of whose clients were in the yacht brokerage business. 

Wednesday, April 8, 2009

Federal Prosecution of UBS Client - Update

The Florida accountant who last week was charged with filing a false federal income tax return because he failed to disclosed his multimillion dollar account at UBS has been released from jail on a $12 million bond. 

Tuesday, April 7, 2009

Innocent Spouse Reg. Invalidated

The Tax Court has invalidated Reg. §1.6015-5(b)(1), which imposed a two year period to apply for Code Sec. 6015(f) innocent spouse equitable relief following commencement of collection action (Lantz 132 TC No. 8).

Monday, April 6, 2009

Is UBS Deferred Prosecution Agreement Paying Off?

On April 2, the DOJ announced that they had charged a Boca Raton, Fla, accountant with filing a false income tax return because he failed to disclose his ownership of a foreign financial account at, you guessed it, UBS. Coincidentally, he also failed to report the income he earned on the account.

The accountant set up his account in Switzerland in the name of a nominee British Virgin Islands corporation. This appears to be the standard ploy UBS used to avoid having to disclose accounts owned by American citizens. UBS bankers, operating in the U.S. apparently told customers to set up entities in offshore jurisdictions and transfer the money to UBS from those offshore accounts. In this way UBS could claim not to know that the offshore accounts were really owned by U.S. citizens and could avoid disclosing the accounts to the IRS.

UBS has admitted that it conspired to defraud the U.S. and agreed to cooperate with the ongoing criminal investigation but to date has disclosed only a few of its U.S. customers who participated in the scheme. UBS also agreed to pay a $780 million fine.

It looks like the U.S. is really serious about cracking down on Americans who hide their money abroad.