Switzerland will release the criteria used to turn over details of 4,450 UBS AG accounts to the Internal Revenue Service today, revealing the U.S. model for chasing tax evaders in other banks and jurisdictions.
There may be as many as a dozen criteria, including accounts containing more than $988,000 and those set up through structures such as foreign trusts or foundations, said William Sharp, a lawyer at Sharp & Associates in Tampa, based on the profiles of clients who were told their account details may be turned over.
"It's already the template on which the IRS is pursuing banks in other countries," Sharp said, adding that Hong Kong, Singapore and Dubai are already under scrutiny. "It will serve as a big wake-up call for any taxpayer found in one of those disjunctive positions."
Switzerland agreed in August to pass on data on some UBS accounts to the United States to settle a lawsuit related to suspected tax evasion.
Swiss authorities withheld details of how the accounts were selected for 90 days so the information didn't interfere with the IRS's voluntary disclosure program.
The Justice Ministry has scheduled a news conference today in Bern to discuss the UBS settlement.