IRS Commissioner Douglas Shulman confirmed Wednesday that the U.S. has reached a settlement agreement with the Swiss government regarding the ongoing UBS battle over the names of U.S. account holders with UBS.

I have received numerous e-mails and calls concerning whether or not CPAs, Accountants and Enrolled Agents should be retaining counsel and using Kovel letters with Offshore Voluntary Disclosures of Undisclosed Foreign Bank Accounts.

The U.S. and Swiss governments have reportedly reached a deal in the on-going UBS litigation saga.  The governments are expected to finalize the details and for the district court of Friday, August 7.  However, sources close to the negotiations say the details of the settlement are unlikely to be released to the public the same day. 

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.