Swiss unveil criteria for tax disclosure on private accounts

U.S. clients with more than 1 million Swiss Francs in offshore accounts with UBS could be ratted out.

American clients who hid more than 1 million Swiss francs in undeclared bank accounts with UBS AG between 2001 and 2008 could have their details turned over to the U.S. government, Swiss officials said Tuesday.

The Swiss government unveiled the criteria used to determine which 4,450 UBS customers risk disclosure to U.S. tax authorities as part of a deal to end major tax evasion investigation against the bank.

They also include Americans, living in the U.S. or elsewhere, who controlled offshore company accounts in 2001-2008, the government said.

Where there is evidence the clients engaged in “fraudulent behavior,” such as by falsifying documents, the threshold for disclosure is lowered to 250,000 francs. Customers who earned an average of over 100,000 francs a year for at least three years will also be targeted.

The equivalent amounts in U.S. dollars vary widely, as the greenback lost over a third of its value against the Swiss franc during the period. One million francs bought about $600,000 in 2001, while seven years later they were worth over $900,000.
Switzerland agreed in August to hand over details about the accounts of up to 4,450 American suspected of serious tax evasion, after UBS acknowledged that its advisers had for years helped thousands of American clients hide billions of dollars from the Internal Revenue Service.

The move was widely seen as a break with Switzerland’s storied tradition of banking secrecy for foreigners, and coincided with a broader effort to shake off the Alpine country’s image as an uncooperative tax haven following sustained pressure from Washington and other major governments.

Swiss authorities have until the end of August 2010 to hand over the names to their U.S. counterparts.

Swiss officials said first 500 American clients have already been selected for disclosure. They can appeal the decision before Switzerland’s top administrative court, which has the final say.

Meanwhile, the IRS said today that more than 14,700 U.S. taxpayers with offshore accounts in 70 foreign countries have come forward to settle their tax debts.
IRS Commissioner Doug Shulman says a flood of people came forward as an Oct. 15 deadline approached for the amnesty program. The program generally allowed people to avoid criminal prosecution if they agreed to pay taxes, interest and penalties.
Shulman says those taxpayers represent billions of dollars in taxes returning to the U.S.