IRS Withdraws UBS "John Doe" Summons

January 21, 2011, 07:16 PM

IRS Commissioner Don Shulman announced on November 16, 2010 that the IRS has now withdrawn its “John Doe” summons against UBS AG Bank thanks to the IRS’s success and cooperation in discovering undisclosed offshore accounts. In August 2009, UBS, the Swiss government and the United States entered into an agreement whereby account holder information on US taxpayers was disclosed to the IRS. As a result of the agreement, the IRS provided a voluntary disclosure program last year and announced that approximately 15,000 voluntary disclosures were made and an additional 3,000 voluntary disclosures have been made subsequent to the close of the voluntary disclosure program. So far, the IRS is asserting that the closed cases have averaged more than $200,000 in tax collections (tax, penalties and interest) per case. Shulman’s announcement echoes his continued priority and focus on combating international tax evasion. Thanks to this success, Shulman anticipates developing new leads with numerous banks, advisors and promoters from around the world. Shulman also touted the benefit of having these taxpayers being brought back into the US tax system and noted that this success is one of many efforts that the IRS is engaged in to increase international tax compliance. Other efforts include the recent reorganization of the Large Business and International Division, a focus of which is to further emphasize and specialize the international and offshore banking effort and continued work with other governments through the Organization for Economic Co-operation and Development. A copy of Shulman’s complete announcement is posted here. –Elaina L. Blanks