Welcome to Chamberlain Hrdlicka's Tax Blog where we provide news and analysis of current legal issues facing tax practitioners.
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Anyone paying attention to the media for the last month or so must be aware of the battle the IRS has waged with UBS in order to obtain information about owners of heretofore “secret” accounts in Switzerland. This is part of an IRS effort to track down tax delinquents who are using overseas accounts to hide their income and assets. A settlement was recently announced whereby the Swiss agreed to reveal a relatively small (in the grand scheme of things) number of the accounts—4,450 versus the 52,000 that the IRS originally alleged—in order to resolve the dispute. At this point, the IRS has its eyes on other foreign institutions and one can be sure that this is not going to be the end of the IRS’ efforts.


