Internal Revenue Service may cast wider net in tax probe

— -- The IRS plans to expand its investigation of wealthy Americans suspected of evading taxes through offshore bank accounts to include bankers, accountants, attorneys and others who may have advised the account owners, legal tax experts say.

Summaries of questions that federal investigators ask owners who disclose their offshore holdings at Swiss banking giant UBS and other foreign banks focus directly on the intermediaries. Provided to USA TODAY by lawyers for UBS clients who have disclosed their assets under an IRS voluntary disclosure program, the queries include:

•Who told the taxpayer about the bank account?

•Who assisted the taxpayer in opening the bank account?

•Who prepared the tax returns?

A form letter the IRS issued last week for use with offshore account owners also seeks names, dates and locations of meetings with "independent advisers/investment managers."

"There is no question that the IRS is targeting other intermediaries," said William Sharp of Sharp & Associates, a Tampa law firm representing Americans with UBS accounts.

"They are interested in learning who helped to set up these structures," said Bryan Skarlatos, a partner at Kostelanetz & Fink in New York that also represents UBS clients from the U.S.

The IRS said the summaries seem to be a compilation of questions to judge eligibility for the disclosure program, which expires Sept. 23.

While saying it would be inappropriate to discuss the investigation, IRS spokesman Frank Keith said that taxpayers making voluntary disclosures and others are providing "new useful information.

"This includes how undisclosed offshore accounts came to be set up and the identities of those who assisted in these efforts to circumvent U.S. tax laws," he said.

The IRS often investigates professional advisers "who put clients into transactions of dubious legitimacy," said Martin Press, a Fort Lauderdale attorney who represents UBS clients.