News & Events

Over the last few years the IRS’s Office of Professional Responsibility (“OPR” or “the Office”) has lived up to its promise of investigating tax practitioners that have been allegedly engaged in questionable conduct related to their advising clients on tax advantaged transactions and preparing tax opinions.  

Swiss banking giant UBS AG (UBS) is facing ongoing pressure on all fronts—from the Department of Justice (DOJ), the Internal Revenue Service (IRS), U.S. Congress, and the international community—to disclose the names of offshore accountholders who use UBS accounts to avoid their taxes.  Federal authorities suspect that approximately 19,000 U.S. taxpayers have used 52,000 UBS accounts to hide $18 billion in assets—or $300 million in tax liabilities.  U.S. UBS accountholders who failed to disclose their offshore accounts to the IRS potentially face major repercussions and should carefully evaluate recent developments. 

The IRS questionnaire for taxpayers seeking to participate in the offshore voluntary disclosure settlement initiative may serve as a device to identify for further investigation practitioners involved in advising clients to use offshore accounts.