According to Reuters, UBS has settled with the IRS.  Names will be named.  (How many?  Yours?  We shall see.)  Beans will be spilled.  Fingers will be pointed.  Bureaucratic chests will be puffed outward. Meanwhile, back on earth. . . . (I have been accused of being obtuse in the past.  By my wife.  Let me [...]

For your reading pleasure, here is Notice 2009-62.  If you have signature power over a foreign financial account but the money isn’t yours, then you have an extension of time to deal with the “Come to Jesus!” clean-up and file all of your paperwork with the IRS. If this applies to your particular situation, it [...]

The Swiss government is thinking about the proposed settlement in the UBS litigation.  (The settlement would have UBS disclose some names, but not the names of all of its 52,000-ish U.S. customers.  Convenient fig leaf for UBS and IRS.) Reuters reports on Swiss cabinet meetings on this point.  From the article, we can see a [...]

Yesterday I posted about the IRS strategy was in the FBAR amnesty process–a quest to identify other Swiss banks, then go after them hammer and tongs (Caution:  sound file) in order to squeeze names of U.S. taxpayers out of them or scare bank customers into voluntary disclosure. Here’s evidence that the hunting strategy is indeed [...]

One of the recurring questions I get is whether going through the amnesty process will cause the IRS to declare open season on all of the prior year tax returns.  Will you be audited for all of your completely unrelated income and deductions if you come forward and declare your previously-hidden offshore bank account? No [...]