Obviously, some people believe these are the most egregious cases, what the government would call the most challenged offenders.  However, others believe, these are some of the names of US citizens that were released to the government by UBS in February.  

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.