August 30, 2009
Reactions to UBS Settlement and Possible Future Prosecutions
Some folks are voicing an opinion on the UBS settlement and what may result from it. Check out the following:
- Reuters, Reactions to UBS tax deal
- Tax.com, Law Professors Express Concern over UBS Settlement
- TaxProfBlog, Tax Profs Criticize UBS Settlement
We have also watched with interest the IRS' efforts to promote voluntary disclosure by US taxpayers prior to IRS' commencement of examination. With the lure of amnesty in the form of no criminal action and reduced civil penalties, the IRS hopes taxpayers will come forward "voluntarily." This general concept is equally laudable. However, the IRS' promise to keep open the September 23 amnesty deadline for taxpayers who come forward even after they receive notice from UBS that their names are about to be revealed is the point at which we depart company with IRS policy.
They state later in their letter:
Our law school operates a low income taxpayer clinic. In the last few years, we have seen an increase in the assertion of penalties against the poorest, least sophisticated taxpayers with virtually negligible room for negotiation by the IRS. It would seem that a blanket program of offering reduced penalties and no criminal action to wealthy, sophisticated tax dodgers who come forward on the eve of their names being turned over to the IRS and with prior knowledge of the forthcoming disclosure, is suggestive of something less than even handed tax administration.
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