Sometimes you guess right. Sometimes you guess wrong. I originally thought that IRS would simply want the 4,450 names of accounts with the highest value. Nope. My sources on the inside now inform me that the IRS went after all accounts held by foreign companies but controlled by US citizens.
That is, if you have not disclosed to the IRS and you are an individual account holder with your now-closed UBS account, there may be a good chance you weren't selected. (Note: the IRS does have other ways of finding you — like when your UBS account was closed, did you leave a money trail behind?)
For those US taxpayers whose foreign entities were the controlling account holders of a UBS account and have not disclosed under the program, there is a lot to be worried about. A criminal indictment may well be coming.
I can see why the IRS wanted these account holders: Because it will be easy to prove the specific intent necessary to convict for tax evasion and conspiracy to defraud.
The IRS and Department of Justice have likely not come after these folks yet as they are clearing their heavy Offshore Voluntary Disclosure files. But when they are done with these, they will be angling for something to do.
Again, it may not be too late. Offshore Voluntary Disclosure Initiative may still be on the table as long as a criminal investigation has not yet started. As of this writing, few UBS criminal investigations have begun.
If you are unsure if you should get into a program, or don't know which program would be best for you, contact us. Call 888-727-8796 or email info@irsmedic.com.
