U.S. and Switzerland Settle UBS Document Request

On August 19, 2009, the United States and Swiss governments announced an agreement to obtain 4,450 names of U.S. taxpayers with accounts in UBS pursuant to the U.S.-Swiss tax treaty. Two principal agreements are involved: a settlement agreement whereby the IRS and UBS resolve their dispute over the John Doe Summons served by the IRS on UBS on July 21, 2008, (the “UBS Summons”) now pending in the U.S. District Court for the Southern District of Florida, Miami Division; and an agreement in which the U.S. and Swiss governments agreed on an information exchange mechanism designed to achieve the U.S. tax compliance goals of the UBS Summons while also respecting Swiss sovereignty (the “U.S.-Switzerland Agreement”)...(more)