[Offshore]

August 2009
Berlin - Swiss banking giant UBS said Wednesday it had agreed to give to American authorities the names of up to 4,450 US account holders who the Internal Revenue Service suspects of using Switzerland's vaunted banking secrecy rules to avoid paying billions of dollars in US taxes.

The announcement ends an eight-month legal battle that strained Swiss-US diplomatic ties, saw UBS agree to pay $780 million in fines, and had Swiss bankers worrying that the secrecy laws that made Zurich synonymous with wealth were under siege.

In a nutshell, the Swiss have said that they will disclose names where there's strong evidence of tax evasion, but not allow fishing expeditions by the US or other foreign governments. The US had at one point said it wanted the names of 52,000 UBS clients.

Nov 18th, 2009
The IRS revealed Tuesday that Swiss authorities did not have to spill the beans on Americans who had less than $248,200 (250,000 Swiss francs) in their accounts or received less than $99,280 (100,000 Swiss francs) in annual revenue from them. According to the newly unveiled annex, however, the Swiss appear to have stretched the definition of that kind of subterfuge. Under the annex, Switzerland defined "fraud and the like" to include failure to provide a W-9 disclosure form for three years if the account met two measures: having more than $992,802 (1 million Swiss francs) at any time from 2001 through 2008, and generating average annual revenue of more than 100,000 Swiss francs over three years.


The agreement also covers accounts of at least 250,000 Swiss francs if the American depositors used an off-shore shell company to hide ownership of the funds and if they engaged in a "scheme of lies." That could include using calling cards to disguise trading orders, and using debit cards, credit cards or loans to mask withdrawals from the Swiss accounts.