Frequently Asked Questions
- I am a UBS customer. Do I have a claim?
On July 17, 2008, the United States Senate Permanent Subcommittee on Investigations released its Staff Report entitled Tax Havens Banks and U.S. Tax Compliance, wherein it reported its conclusions from an investigation of the offshore banking service provided to United States customers by UBS AG. If you held an account with UBS in Switzerland at any time from 2000 to 2007 and have been or are being audited or investigated by the Internal Revenue Service or other taxing authority as a result of activity in such account, you may have a claim against UBS and other promoters or advisors who recommended the UBS offshore account. If this describes your circumstances, we would welcome the opportunity to discuss your situation.
- What did the government conclude about UBS’s offshore banking practices?
On July 17, 2008, the United States Senate Permanent Subcommittee on Investigations released its Staff Report entitled Tax Havens Banks and U.S. Tax Compliance, wherein it reported its conclusions from an investigation of the offshore banking service provided to United States customers by UBS AG. The Subcommittee concluded, among other things that UBS employed banking practices that could facilitate, and have resulted in, tax evasion by their U.S. clients; UBS has accounts in Switzerland for an estimated 19,000 U.S. clients with assets valued at $18 billion that have not been disclosed to the IRS; and UBS assisted their U.S. clients in structuring their foreign accounts to avoid U.S. reporting requirements.
View the full text of the Senate Report. - I just received a notice from the IRS regarding my UBS offshore account. What do I need to do?
We are not tax attorneys and do not represent clients before the Internal Revenue Service (“IRS”). We represent taxpayers in civil litigation against the law firms, accounting firms, and investment firms that designed, promoted, and implemented the tax strategies that may have led to scrutiny from the IRS. However, over the last 6 years, we have worked with our clients’ tax counsel to coordinate and implement a forward-looking, big picture, litigation strategy that served our clients dual needs in connection with their civil litigation and IRS proceedings. We believe that through these coordinated efforts, our clients were able to thoroughly assess all of their options and make informed choices that were in their best interests. We would be happy to discuss with you or your tax counsel the ways that we could serve your civil litigation needs.
- I participated in a Sale-In, Lease-Out (“LILO/SILO”) transaction. Can you help me?
If you have been or are being audited or investigated by the IRS in connection with your LILO/SILO transaction, you might have civil claims against the advisors or promoters that recommended the transaction to you. We have extensive experience in pursuing these types of civil claims against promoters and advisors and would welcome the opportunity to discuss your situation.
However, we are not tax attorneys and do not represent clients before the Internal Revenue Service (“IRS”). If you have received a notice of audit from the IRS in connection with the transaction, you should contact a tax attorney FIRST to discuss your options in how to resolve your tax dispute with the IRS. We would be happy to discuss with you or your tax counsel the ways that we could serve your civil litigation needs.