The IRS said today that it is planning to issue additional John Doe summonses to catch American clients of offshore banks beyond UBS. According to the bloomberg story by Ryan Donmoyer, IRS Expanding Offshore bank Probe Beyond UBS, Apr. 27, 2009, information on the new banks involved, which have not yet been identified, turned up in the course of the UBS investigation, through whistleblowers and other channels. "There has been an evolution of data and information that we're getting from a variety of sources," said John McDougal, an IRS trial lawyer appearing at a conference in Miami Beach, Florida.
One expects that information may also be coming in from US taxpayers who have self-identified in the course of the UBS probe, as the IRS asks detailed questions about the handling of accounts, to find out who is promoting or giving advice on such offshore tax-escape devices. See, e.g.,Barrett, IRS Squeezes Swiss Bank Clients for Evidence, AP News, Mar. 26, 2009.
UBS agreed to pay $780 million in fines and penalties to avoid prosecution for helping taxpayers hide money in Swiss accounts, and the US is still seeking information on about 52,000 UBS accounts.
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