Voluntary Disclosure Update for U.S. UBS Clients

William M. Sharp Sr. & Larry R. Kemm (both of Sharp & Associates, Tampa) have published Voluntary Disclosure Update for U.S. UBS Clients, 52 Tax Notes Int'l 487 (Nov. 10, 2008):

Because of recent developments, U.S. taxpayers who maintain undisclosed accounts with UBS AG in Switzerland will be required to close their accounts. Many taxpayers are seeking guidance to address U.S. legal and tax issues related to becoming U.S. tax compliant. One way to become compliant with U.S. law while also minimizing U.S. criminal and civil tax exposure is through the Internal Revenue Service's voluntary disclosure program.

For prior TaxProf Blog coverage, see The UBS Summons and IRS Voluntary Disclosure (9/28/08).  See also Washington Post: UBS Is Closing Down Accounts; U.S. Clients at Risk of Exposure, by David S. Hilzenrath:

Swiss banking giant UBS, under investigation by the U.S. government for allegedly helping Americans hide money from the IRS, is closing thousands of accounts, putting clients at greater risk of being exposed, tax lawyers say.

UBS clients have been receiving calls and letters telling them that their Swiss accounts will soon be liquidated. Those who have concealed funds from the IRS have two basic choices: They can take new and potentially difficult steps to hide the money, heightening their risk of being caught and punished severely, or they can come clean, lawyers say.