The U.S. Tax Court held July 8 in a case of first impression that it has jurisdiction under section 7623(b)(4) to consider a whistleblower's appeal of an award determination by the IRS Whistleblower Office. (For William Prentice Cooper III v. Commissioner, 135 T.C. No. 4 (Jul. 8, 2010), see Doc 2010-15202  .)

In what is seen as a blow to the famous Swiss banking secrecy laws, the Swiss Parliament resolved its split over the UBS account information disclosure issue when the lower house voted on June 15th to effectively overturn the Swiss court’s ruling that was temporarily blocking the agreement between UBS and the U.S. government.  Under the terms of the agreement, the U.S. government agreed to not prosecute UBS for its actions in assisting US tax evaders if UBS disclosed the names and account details of its 4,450 largest accounts held by US citizens suspected of tax evasion.

On February 24, 2010, the Swiss government announced that it will seek parliamentary approval to effectively overturn a Swiss Court’s efforts to block the release of information identifying U.S. accountholders at UBS AG (“UBS”) to U.S. authorities.  In the meantime, pending parliamentary approval, Swiss tax authorities are continuing to process U.S. requests for information on U.S. clients of UBS.

The IRS has given U.S. taxpayers participating in the IRS Offshore Settlement Initiative Program (“the Initiative”) until January 15, 2010 to provide additional information to the IRS concerning offshore accounts.  Thus, U.S. taxpayers with accounts in foreign banks have just over 2 weeks to make a complete voluntary disclosure of their accounts to the IRS or risk facing increased monetary penalties – which can exceed the value of the account – and potential criminal prosecution.  Taxpayers who failed to enter the Initiative may still potentially take advantage of the reduced penalty framework by filing before January 15, 2010.