More than 150 wealthy American customers of Swiss banking giant UBS ubs are under investigation for suspected tax evasion, federal prosecutors disclosed Tuesday.
The glimpse at the breadth of the probe of Americans who may be hiding offshore assets from the IRS came in a Florida federal court filing as UBS prepared to give federal authorities the names of other U.S. clients expected to face similar investigations.
Details of the handover, expected as soon as today, "will produce the identities and account information of additional UBS customers who are believed to have violated United States law," acting U.S. Attorney Jeffrey Sloman said in the court filing.
Florida tax attorney Martin Press and other lawyers for UBS clients say they expect the bank will provide data for thousands of U.S. account holders — but not for all of the estimated 52,000 customers the IRS demanded in a lawsuit. The handover stems from a settlement in that case last week.
The 150 Americans targeted by prosecutors are among more than 250 U.S. clients of UBS whose financial data the bank gave to U.S. investigators earlier this year because their accounts bore signs of tax evasion. Besides providing the data, UBS agreed to pay $780 million to defer prosecution of criminal charges that it sent its bankers on secret trips to the U.S. to help customers hide assets.
So far, three of the clients whose accounts were included in the first UBS handover have pleaded guilty to filing tax returns that failed to report millions of dollars in assets or income. A fourth is set to plead guilty in September to charges of failing to report a UBS account allegedly used to evade taxes on more than $1 million in business income.
In all four cases, the UBS clients disguised their ownership of the secret accounts by controlling them through entities in Hong Kong, Panama or the British Virgin Islands, court records show.
Tuesday's court filing came in the case of Bradley Birkenfeld, a former UBS banker who pleaded guilty last year to charges he conspired to help some of the bank's American clients evade taxes. Cooperating with prosecutors, he provided secret details of UBS' strategies for its U.S. clientele.
Birkenfeld faces a maximum five-year federal prison term at a scheduled Friday sentencing in Fort Lauderdale. But prosecutors, citing his "substantial assistance," recommended a 2½-year sentence.
Defense attorney Robert Stickney wrote separately that Birkenfeld's "extraordinary" cooperation merited five years' probation.