UBS Tax Ruling May Prompt Fresh U.S. Legal Battle
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UBS Tax Ruling May Prompt Fresh U.S. Legal Battle
By David Voreacos, Carlyn Kolker and Klaus Wille
A Swiss court ruling that impedes the Internal Revenue Service’s ability to collect data on 4,450 UBS AG accounts may prompt the U.S. to revive a lawsuit that shaped the IRS crackdown on offshore tax evasion.
The case involves an Aug. 19 agreement by UBS, the biggest Swiss bank, to settle a U.S. suit seeking data on clients suspected of dodging U.S. taxes. UBS ended the case by agreeing to hand over 4,450 accounts involving “tax fraud or the like.”
That accord violated Swiss law by defining fraud too broadly, Switzerland’s Federal Administrative Court ruled in an opinion released Jan. 22. The ruling may force the U.S. back into federal court in Miami to challenge UBS, New York tax lawyer Bryan C. Skarlatos said.
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