IRS Names New International Tax Official

The Internal Revenue Service announced Wednesday that Michael Danilack has been named deputy commissioner for international tax matters.

Danilack joins the IRS from the Washington, D.C., office of tax boutique Burt, Staples & Maner. The 15-lawyer firm also has an office in London, with a roster of clients including Citigroup, Credit Suisse, Euroclear and UBS.

Prior to joining the firm, Danilack worked as a principal at Deloitte Tax, focusing on cross-border tax matters. From the mid-1990s to 2000, he served as IRS associate chief counsel (international) overseeing the legal staff responsible for the interpretation, enforcement and litigation of all international provisions of the U.S. revenue laws.

via IRS Names New International Tax Official.

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Swiss to Reveal Tax Man Tactics

Switzerland will unveil the criteria behind the disclosure of 4,450 UBS accounts handed over to U.S. tax officials at a press conference tomorrow, Bloomberg reports.

As part of a late summer settlement between UBS and the U.S. government, the Swiss banking giant agreed to hand over the names on those UBS accounts. (UBS paid $780 million in February to settle criminal charges that the bank helped wealthy American clients avoid paying U.S. taxes.)

Swiss officials are expected to reveal the model used by IRS and Justice Department lawyers to suss out overseas tax evaders. The Am Law Daily reported in August that the Justice Department might never release an appendix to its UBS accord detailing the criteria used to select the 4,450 accounts, because it doesn't want to tip its hand on disclosure requirements and possibly incentivize individuals not to come forward under an amnesty program.

The amnesty deadline for U.S. citizens to file income tax returns disclosing assets stashed away in offshore tax havens passed on October 15. Swiss authorities withheld details of how UBS accounts were selected so as not to interfere with the IRS's voluntary disclosure program, which saw about 7,500 Americans submit filings.

Now the country's Justice Ministry–making more headlines recently for its role in the Roman Polanski case–will announce more intimate details of its arrangement with U.S. regulators. According to Bloomberg, the criteria will likely be based on a point system that automatically triggered the disclosure of certain accounts.

Like speeders getting pulled over by state troopers on a highway, certain accounts would accrue points based on certain characteristics. Have a million Swiss francs in your local savings bank in lakeside Lucerne? That's a point. Financial arrangements structured as foreign trusts and foundations also are fertile ground for red flags, Bloomberg reports.

The IRS has recently opened new offices in Beijing, Panama City, and Sydney as part of its effort to crackdown on overseas tax havens for U.S. citizens. Bloomberg recently reported that Hong Kong has become a target for federal prosecutors keen on determining how the roles financial professionals possibly linked to tax evasion have evolved after the former British colony was returned to China in 1997.

Read more:  Swiss to Reveal Tax Man Tactics.

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