Thanks to UBS, we now have a blueprint of how the IRS and DOJ will shape their tax evasion investigations vis-a vis offshore accounts.

The IRS Offshore Account Voluntary Disclosure Program (the “Program”) is over.  But that does not mean U.S. taxpayers with undisclosed foreign bank accounts should stay in hiding.  In fact, the relative success of the Program makes it imperative for people with still undisclosed accounts to come forward and make a voluntary disclosure.

Now we know how UBS will determine which U.S. clients to turn over to the IRS.

As anticipated, undisclosed government sources have confirmed that the IRS is extending the deadline for U.S. taxpayers with undisclosed foreign bank accounts to come forward and participate in the special voluntary disclosure settlement initiative.

U.S. authorities have been very busy negotiating agreements with other counties that will make it easier for the U.S. to identify and prosecute U.S. taxpayers hiding money and assets overseas.