UBS/Tax Haven IRS Audit Program

Recent amendments to international tax treaties indicate changes to IRS policies regarding audit for foreign-situated monies. New tax treaties especially affect United States citizens with income in Switzerland, Singapore, Hong Kong, Luxembourg, Lichtenstein, and Monaco. The IRS has issued “John Doe” summons to several international banks, seeking information regarding individuals who have unreported foreign income.

The IRS has established a program for voluntary disclosure, the deadline for which was recently extended through 15 October 2009. In the event you operate a business overseas, maintain a foreign bank account, or earn income abroad, you may be obligated to make certain reports to the IRS. If you have not filed returns disclosing such, it may be in your best interest to, at a minimum, examine as soon as possible whether a reporting obligation existed and was missed.

It is important to bear in mind, however, that there are many legitimate reasons for individuals and businesses to maintain assets abroad and earn foreign-sourced income. The recent audit activity by the IRS, and well-publicized actions concerning banks such as UBS, should not discourage U.S. citizens from the appropriate use of foreign accounts – even accounts in jurisdictions with so-described “secrecy” laws regarding account holders.

In 1992, Tom Stevens left government service as a special assistant attorney general addressing tax matters. Since then, he has developed substantial experience negotiating with the IRS for structured tax payments for individuals and businesses. As an admitted solicitor in England and Wales, he also has significant familiarity with implication of international law and tax treaties.

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