Over the past 10 years, the government has fought a steadily escalating war against tax fraud. The first phase of this battle was directed primarily at so-called “abusive” tax shelters and has led to the investigation and prosecution of accounting firms, law firms, and financial institutions involved in the marketing or implementing of those shelters.
The second phase of the government’s attack is targeted at taxpayers directly, and, in particular, at wealthy individuals who secreted assets in foreign bank accounts. The government has fought doggedly to force foreign banks to disclose the identities of U.S. account holders. The government achieved a significant victory in August 2009 when it settled a summons enforcement action with UBS, pursuant to which UBS agreed to provide the identities and account information of approximately 4,450 clients who failed to report income earned in undeclared Swiss bank accounts.1
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