"Today's agreement marks the final resolution with UBP, which acknowledges its role in conspiring with U.S. taxpayers to evade U.S. tax through an array of sham entities, structured transactions, nominees, and bank services designed to disguise the true ownership of foreign accounts and other assets," said Caroline Ciraolo, acting assistant attorney general of the DOJ Tax Division.
The non-prosecution agreement marks the 76th category 2 agreement and brings the total penalties collected to just over $1.3 billion. Previously, Ciraolo had indicated that all resolutions under the program would be completed by December 31, 2015. But she told Tax Analysts that there are more pending NPAs and that this announcement brings the Justice Department "one step closer to completing those pending agreements."
The terms of the agreement require UBP to cooperate in any related criminal or civil proceedings and demonstrate its implementation of controls to stop misconduct involving undeclared U.S. accounts.
UBP managed approximately 2,919 U.S.-related accounts during the period subject to penalty, a figure that includes both declared and undeclared accounts. The bank's peak assets under management reached $4.9 billion during the years in question.
"Today's agreement is significant on several fronts," Richard Weber, IRS Criminal Investigation division chief, said in the press release. "This agreement will have far-reaching implications, expanding our understanding about the depth, breadth, tactics, and techniques employed by the UBP private bankers and external asset managers who assisted U.S. taxpayers to conceal assets not only in Switzerland, but in other jurisdictions as well."
About Tax Analysts
Tax Analysts is an influential provider of tax news and analysis for the global community. Over 150,000 tax professionals in law and accounting firms, corporations, and government agencies rely on Tax Analysts' federal, state, and international content daily. Key products include Tax Notes, Tax Notes Today, State Tax Notes, State Tax Today, Tax Notes International, and Worldwide Tax Daily. Founded in 1970 as a nonprofit organization, Tax Analysts has the industry's largest tax-dedicated correspondent staff, with more than 250 domestic and international correspondents. For more information, visit our home page.
For reprint permission or other information, contact firstname.lastname@example.org