July 15, 2010 – Swiss court allows UBS account holder’s information to be disclosed to U.S.

IRS had announced that it settled its dispute over John Doe summons subsequent to entering in agreement with Swiss government. On July 15, 2010, Switzerland’s Federal Administrative Court rejected a UBS account holder’s complaint that sought to prevent the release of her client information to the U.S. tax authorities. The verdict may not be appealed. The ruling, made public on July 19, 2010, found that the taxpayer’s account satisfied the requirements to be turned over under the Switzerland-U.S. agreement signed in August 2009 where the Swiss authorities agreed to hand over the account information on 4,450 persons with undisclosed accounts at UBS. The court also noted that the Switzerland-U.S. agreement was binding as it was ratified by Swiss parliament on June 17, 2010. The ruling is significant insofar as it signals the likely end-game for UBS account holders with undisclosed accounts who had sought to prevent their account information from being delivered to the IRS.

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