Saturday, July 24, 2010

Update on Swiss Turnover of Documents Pursuant to Treaty Request (7/24/10)

I reported earlier today that the Swiss Administrative Court has approved the treaty request, thus opening the door to turnover of the 4,450 U.S. taxpayer UBS records. 

A Tax Notes Today article on 7/23/10, provides some additional information on the turnover status.  David D. Stewart, Swiss Court Blocks Transfer of Two UBS Files Pending Review, 2010 TNT 141-9 (7/23/10).  The author notes that two U.S. taxpayers have gotten a reprieve to the turnover pending further hearing. It is unclear whether this is just a slight temporal victory for those two taxpayers.

The author further notes:
So far, details about 2,500 of the estimated 4,450 UBS accounts of U.S. taxpayers have been transmitted to the IRS, according to a July 19 report in Neue Zürcher Zeitung. Nine hundred files are still being considered, and 850 have been completed but are still within the period during which an appeal can be considered. Ninety-six appeals have been filed, according to the report, and of those, 80 are similar to a separate appeal that was dismissed. * * * *

The agreement requires the FTA to complete the processing of UBS client files by August 26.

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