Swiss Parliament Gives Green Light to Disclose United States Taxpayers’ Names to Internal Revenue Service
June 17 – The lower house of the Swiss Parliament gave in to pressure from the upper house to not seek a popular referendum on the U.S. - UBS disclosure agreement. After finally voting to approve the agreement earlier this week, the lower house had stipulated that they wanted the issue to go through the country’s complex referendum process, presumably so that they were not held politically liable for the agreement to their constituents next election cycle.
This agreement not to pursue the referendum makes the U.S. – UBS deal final. The Swiss tax authorities are working to gather the information required by the U.S. – UBS deal for delivery to the IRS before the August deadline.
We have every expectation that this deadline will be met, that the IRS and the Department of Justice will obtain the remaining 4500+ names, and that investigations of all identified U.S. taxpayers will begin in the coming months.
What does all this mean? The UBS account holders that have not come forward will almost certainly be investigated by the Criminal Investigation Division of the Internal Revenue Service and will potentially face criminal charges and severe civil sanctions.
Of course, prosecution and sanctions are not limited to U.S. taxpayers who failed to disclose UBS accounts. The U.S. government has been very vocal about pursuing U.S. taxpayers at other foreign banks as well. Sources within the U.S. government have indicated that agreements similar to the very public one with UBS have been or are in the process of being completed with other foreign banks in Switzerland and other countries.