June 24, 2009 - Phil Hodgen

Litigation pressure remains on UBS for disclosing names

The United States and Switzerland are busily renegotiating their bilateral income tax treaty. No doubt the new treaty will provide for many new ways in which Switzerland can disclose financial information about U.S. persons with bank accounts in Switzerland.

Does this take the pressure off UBS in the lawsuit now grinding along in Florida? No.

In today’s Tax Notes Today there is an article stating that the U.S. government intends to push forward for a court order requiring UBS to cough up the names of its U.S. customers:

The Justice Department has no plans to withdraw the IRS John Doe summons against Swiss bank UBS AG, the department said June 23.

In response to reporters’ queries about a June 23 report in The New York Times that quoted a “United States official briefed on the matter” as saying that the DOJ may drop the summons, the DOJ said in a statement that “there is no basis for the report in The New York Times.”

I think Isaac Newton’s laws might have something to say about bureaucratic behavior – a body in motion remains in motion, etc. 🙂

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