IRS Wins Right to Serve Summons on Swiss Bank

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Do you have an account with UBS? The IRS might be taking a closer look at it, if you do.

Just one day after the Justice Department asked a federal court to allow the IRS to serve “John Doe” summonses on UBS AG (based in Switzerland), one of the world’s largest banks, the court approved the request. UBS is under investigation for allegedly helping Americans to hide as much as $20 billion in assets using fraudulent tax schemes, over a 7-year period from 2000 to 2007.

The government’s allegations apparently stem from the recent guilty plea of a former UBS employee in federal court. The employee pled guilty to helping U.S. taxpayers create offshore sham entities to act as foreign beneficial owners of the offshore accounts. The IRS has taken the position that the scheme enabled U.S. taxpayers to avoid filing Forms W-9 identifying them as such, which consequently meant that UBS would not report the U.S. taxpayers’ identities or their income to the IRS. And, where there is a reasonable basis to believe that a group of persons may have failed to comply with tax law, the government can apply for “John Doe” summonses, rather than having to produce individual names. Adding to UBS’ woes, German authorities are also considering similar action.

The sad part is, even with all of the doom and gloom, tougher-IRS, loopholes-closing, state-sales-tax issues we’ve been talking about recently, there are still plenty of ways to save money and protect your assets without using questionable or illegal tax structures. I’ve been working with Diane on tax strategies for several months now, and I’m amazed at the amount of money that is consistently being saved. It’s also great to talk with so many people who are creating successful businesses and real estate portfolios, even in the face of a tough economy. And I like the fact that we can provide such a good blend of asset protection and tax strategies.

I guess there’s no great lesson here today (other than if it sounds to good to be true it probably is). But if you are looking for a safe and legal way to cut your tax bill, Diane’s tax strategy service is a great place to start. Drop Richard Cooley a line at if you’re interested.


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