A federal judge has authorized the IRS to seek records from UBS AG, of U.S. taxpayers suspected of hiding their income in accounts with Swiss bank Wegelin.A US federal court has granted the Internal Revenue Service's request for a disclosure order against UBS, which acted as US correspondent bank for the now-defunct Swiss Bank Wegelin, handling…Read more
Swiss to Accept Group Requests for Bank Information From Other Countries Starting Feb. 2013.
Switzerland will be able to provide banking and other details sought by other countries, that have concluded agreements with Switzerland on administrative assistance in tax matters to file “group”requests for information on their nationals suspected of tax evasion, even without their individual identification, provided the information has not been requested as part of some ‘fishing expedition’.A…Read more
Significant Changes in Final FATCA Regulations
As we have reported on January 17th, in our post IRS Issue Final Regulations to Combat Offshore Tax Evasion, the US Treasury Department published final rules governing enforcement of the Foreign Account Tax Compliance Act (FATCA). The Final Regulations make a number of changes to the extensive proposed regulations released last February, in particular: All debt…Read more
CCM 201250020 – Use of Third-Party Return Information In Captive Insurance Audits
The Office of Chief Counsel, Internal Revenue Service, issued Chief Counsel Memorandum 201250020 on Dec. 14, 2012 stating that: "The Service may disclose the third party return information in the exams of the unrelated taxpayers to the extent the documents satisfy the “item test” of section 6103(h)(4)(B)." The documents satisfy the “item test” if they directly relate to…Read more