Get in Line Brother # 13 - Quickly for UBS Account Holders

The Wall Street Journal has an informative, albeit tentative, article here today on the status of the UBS - U.S. spat over foreign accounts. The newspapers and internet are still buzzing about the possibility of a settlement. The general expectation from those sources is that a settlement would require UBS to cough up a lot more names, although perhaps not near the 52,000 names that has been bandied about. I won't speculate about the possibility of a settlement or even the possibility that the U.S. will get many or any more names.

A takeway point from the WSJ article is that some practitioners believe that a UBS disclosure of names of persons not yet in the Voluntary Disclosure program will close off their opportunity to join the program. I quote the article:

If UBS discloses names and information as part of a settlement, the IRS will “generally not accept a voluntary disclosure from anyone on that list,” says Mr. Michel. Further, he adds, a settlement in this case “could come any day and be accompanied by disclosure.” So, unless the IRS gives everyone until Sept. 23, the expiration date for a settlement initiative now in place, the window for voluntary disclosures may be closing fast for many.

The Mr. Michel quoted is a prominent attorney in this area of the law (see bio here).

So, the message is the steady drumbeat -- Get in Line Brother, but do so Quickly.