IRS Voluntary Disclosure Program Update

U.S. Accounts To Be Disclosed Under U.S.-Swiss Settlement Agreement: "Amnesty" For Undisclosed Offshore Accounts Expires September 23, 2009

On August 19, 2009, the Internal Revenue Service (IRS) and the U.S. Department of Justice announced a settlement agreement with UBS regarding certain accounts held at the bank by U.S. persons. The offshore voluntary disclosure program announced in March 2009 is scheduled to expire on September 23, 2009. IRS Commissioner Doug Shulman has stated there is no "present intent" to extend this deadline. This deadline and the widely reported negotiations on account-holder name disclosure between the IRS and Swiss banking and governmental authorities indicate that U.S. persons may want to promptly examine any interests they may have in undisclosed foreign accounts and, where appropriate, take steps to comply with the emerging IRS protocols relating to these accounts.