The US Department of Justice recently determined that the Singapore affiliate of UBS (UBS AG) "has complied with an Internal Revenue Service (IRS) summons for bank records" related to a taxpayer whose liabilities are at issue. The international financial institution refused to produce the records when first served the summons. After a petition was filed to enforce the summons formally, UBS and the IRS resolved the matter amicably and the petition was voluntarily dismissed.
As a significant player in the offshore account market, UBS essentially has an obligation to its clients, stakeholders, and foreign regulatory authorities to refuse to comply with such summonses. It is unclear why UBS did not wait for a formal order to produce the taxpayer's records to the IRS, particularly considering that Singapore does not have any tax treaty in effect with the US.
If you have not yet disclosed your foreign accounts to the IRS, you should consider participating in one of their offshore voluntary disclosure programs today. Contact our office for more information.