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52,000 Tax Evaders Now Holding Financial World Hostage

Tyler Durden's picture




According to Reuters, the amended deal between the IRS and Switzerland to cut down the number of disclosures from 52,000 to 5,000 comes on the heels of the understanding by the US Treasury that after Goldman and CRE, it is now 52,000 tax cheats who hold the financial world hostage. Apparently if all the 52,000 tax evaders fled from UBS, it would spell the end of the world (once again).

"NZZ am Sonntag said the U.S. government had backed off from the original demands of the Internal Revenue Service (IRS) because the U.S. Treasury Secretary did not want to provoke another financial crisis by pushing UBS over the edge."

At what point with Tim Geithner show a modicum of backbone and actually do the right thing instead of bowing to pressure from any which direction? The irony is that for all intents and purposes Swiss bank secrecy is over:

NZZ am Sonntag said the names of those to be disclosed would be those suspected of committing tax fraud under the terms of the double taxation agreement, which obliges Switzerland to provide help if Washington seeks it in a criminal investigation.

Accounts below a certain size would not be reported, but this limit would be kept confidential so that account-holders could never be sure whether they were vulnerable, it said.

However, account-holders threatened with disclosure would be able to challenge the move in the Swiss courts, it said.

Some observations here: First, the CHF is likely about to tank. While a net dollar positive, this may in fact benefit Europe and specifically the CRE and residential bubble, especially in Central and Eastern Europe, where mortgages are mostly denominated in Swiss Francs. Undoubtedly, this has been a long-term consideration of the US Treasury and the Federal Reserve. Second, with all the money that is about to surface from previously undisclosed bank accounts, estranged wives of husbands who somehow are suddently hundreds of millions of dollars richer, will make divorce very, very happy. Look for a flood of divorces over the next several months as the battle for the spoils picks up in earnest.

And here is the official IRS press release:

IRS to Receive Unprecedented Amount of Information in UBS Agreement
 
IR-2009-75, Aug. 19, 2009

WASHINGTON — The Internal Revenue Service and the Department of Justice today announced the successful negotiation of an agreement that will result in the IRS receiving an unprecedented amount of information on United States holders of accounts at the Swiss bank UBS.

As a result of this agreement, the IRS will receive substantially all of the accounts that it was interested in when it initiated the John Doe summons against UBS.

Under the agreement, the IRS will submit a treaty request to the Swiss government describing the accounts for which it is requesting information. The Swiss government will then direct UBS to initiate procedures to turn over information on thousands of accounts to the IRS. The IRS will receive information on accounts of various amounts and types, including bank-only accounts, custody accounts in which securities or other investment assets were held and offshore company nominee accounts through which an individual indirectly held beneficial ownership in the accounts.

Also, the agreement retains the U.S. Government’s right, if the results are significantly lower than expected and other measures fail, to seek appropriate judicial remedies, including resuming actions to enforce the John Doe summons.

The agreement involves a number of simultaneous legal actions:

  • The judicial enforcement of the John Doe summons will be dismissed. While this enforcement motion will be withdrawn, the underlying summons remains in effect.
  • Upon receiving the treaty request, the Swiss government will direct UBS to notify account holders that their information is included in the IRS treaty request. It is expected that these notices will be sent on a rolling basis with some being sent over the coming weeks and others over the coming months. Receipt of this notice will not by itself preclude the account holder from coming into the IRS under the Voluntary Disclosure Program.

In addition, the Swiss Government has agreed to review and process additional requests for information for other banks regarding their account holders to the extent that such a request is based on a pattern of facts and circumstances equivalent to those of the UBS case.

Information provided to the IRS through this process will be thoroughly examined for all potential civil and criminal tax violations. The IRS will assess any additional tax, interest and a number of applicable penalties. This includes the penalty for the willful failure to file an FBAR. This penalty can be up to 50 percent of the value of the account for each year an FBAR was not filed.

The IRS will also recommend criminal prosecution in those cases where the facts warrant such an action. To date, the IRS and the Department of Justice have successfully prosecuted four United States customers of UBS whose information was provided to the IRS by UBS as part of the Deferred Prosecution Agreement.

Individuals whose information is obtained by the IRS through this process will, by longstanding policy, not be eligible for the voluntary disclosure program.




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Wed, 08/19/2009 - 11:14 | Link to Comment Sqworl
Sqworl's picture

No Doubt!! it would kill our goverment!!! Just imagine what Nancina Piglosi looks like without Botox!

Wed, 08/19/2009 - 14:53 | Link to Comment Anonymous
Wed, 08/19/2009 - 11:16 | Link to Comment Mos
Mos's picture

"where mortgages are mostly denominated in Swiss Francs."

I thought it was Euros?  How big an impact will the devaulation of the Franc have on keeping the Eastern European banks alive on life support?

Wed, 08/19/2009 - 11:19 | Link to Comment Sqworl
Sqworl's picture

High Five Mos!!...you now have imunity from attacks...;-)

Wed, 08/19/2009 - 11:21 | Link to Comment zeropointfield (not verified)
Wed, 08/19/2009 - 11:27 | Link to Comment Cheeky Bastard
Cheeky Bastard's picture

no, they were taking out mortgages in CHF because the interest was lower than on EUR denominated loans. It was massive couple of years ago. I can only speak for central Europe, but i don't think Russians took out CHF loans or mortgages; but USD ones. Also I am sure Baltic states were ape shit insane over JPY carry. And its not E.Eur banks you need to keep an eye on; but on Austrian, Belgian and Italian ones. Austrian banks lent out 70% of Aus. GDP to Russians and Ukrainians. And check out the latest RIA report ( its scary ).

Wed, 08/19/2009 - 11:44 | Link to Comment Ben_the_Bald
Ben_the_Bald's picture

It's not the Eastern European banks that you have to be worried about, it's the Austrian banks who borrowed in Swiss francs from Swiss banks to lend to Eastern Europe that are at risk first. Of course, it also affects other EU banks, but the situation in Austria is much more severe.

It's ugly out there:

http://seekerblog.com/archives/20090222/eastern-europe-meltdown-impact-o...

Wed, 08/19/2009 - 13:36 | Link to Comment Jeanbon
Jeanbon's picture

what I know is that Austrian Banks are

strong in Yen lending. I know that in Switzerland,

where rates are incredibly low, people started to

lend in Yen, with Austrian Banks, because they thougth

they could make money in Yenswissi, because the Yen

fell. Once the big deleverage started, yenswissi

jumped from 1,00 to almost 1,30 in a heart beat.

Our financial system is so fucked up, once the liquidity

of the central banks runs out,  they will have to explain...

 

Wed, 08/19/2009 - 17:02 | Link to Comment iknowNOW (not verified)
Wed, 08/19/2009 - 13:31 | Link to Comment Jeanbon
Jeanbon's picture

During the boom years, tons of credits have been 

given to eastern europe in CHF. During the crisis,

CHF exploded to the upside, and thats a huge problem

for the debts in these eastern countries. Now they

have 50 % more debt, and pay 50 % more interest.

The Swiss Central Bank tried, during the past months,

to weaken the CHF, saying, it is for the interest of the

countries exports. But in reality, there is this huge

bubble of CHF credit, that has been placed abroad.

As long as we do not get the proof, that non swiss

start to take their money from swiss banks, it will be

The USD, that calls the shots.

At 78,5 & 77.5 stand the last good supports for the DXY,

The Swiss Central Bank is so small vs. the FED & EU central

banks, they would need ALL printing machines on the world

to weaken the currency at this point.

 

 

Wed, 08/19/2009 - 11:18 | Link to Comment zeropointfield (not verified)
Wed, 08/19/2009 - 11:51 | Link to Comment bpj
bpj's picture

Keep in mind that there is no statute of limitations on IRS faux pas, no right to a jury, and failing to report monies (not income) in foriegn holdings is a crime.

Wed, 08/19/2009 - 12:23 | Link to Comment Anonymous
Wed, 08/19/2009 - 16:29 | Link to Comment Anonymous
Wed, 08/19/2009 - 11:20 | Link to Comment Cheeky Bastard
Cheeky Bastard's picture

from a Swiss to the IRS: FUCK YOU !!!

Wed, 08/19/2009 - 11:41 | Link to Comment Rex Havoc
Rex Havoc's picture

From a Sicilian to the IRS - FUCK YOU as well!

Wed, 08/19/2009 - 11:50 | Link to Comment Cheeky Bastard
Cheeky Bastard's picture

+100 dude  

Wed, 08/19/2009 - 11:21 | Link to Comment Anonymous
Wed, 08/19/2009 - 11:30 | Link to Comment B_Movie
B_Movie's picture

did he say we have to honor contracts ...LOL.

could those contracts be paid if it weren’t for the taxpayer’s money?

EDIT he=Arthur Levitt

Wed, 08/19/2009 - 11:27 | Link to Comment Anonymous
Wed, 08/19/2009 - 11:27 | Link to Comment Anonymous
Wed, 08/19/2009 - 11:29 | Link to Comment Anonymous
Wed, 08/19/2009 - 17:18 | Link to Comment Anonymous
Wed, 08/19/2009 - 11:30 | Link to Comment Anonymous
Wed, 08/19/2009 - 11:35 | Link to Comment Cheeky Bastard
Cheeky Bastard's picture

check out this bat-shit insane ( yet highly probable ) article from Denninger http://market-ticker.org/archives/1349-Depression-Assured-Maybe-Swine-Flu.html

Wed, 08/19/2009 - 11:44 | Link to Comment Dixie Normous
Dixie Normous's picture

wow, just, wow.

Wed, 08/19/2009 - 12:53 | Link to Comment rigger mortice
rigger mortice's picture

death rate from swine flu hasn't hit the UK that much.there are many cynics who allege that it's being used to cover up the scale of the global financial clusterfuck

Wed, 08/19/2009 - 13:16 | Link to Comment Milton
Milton's picture

Nah, someone is long NVAX.

Wed, 08/19/2009 - 11:36 | Link to Comment Anonymous
Wed, 08/19/2009 - 11:40 | Link to Comment Anonymous
Wed, 08/19/2009 - 11:40 | Link to Comment Anonymous
Wed, 08/19/2009 - 12:52 | Link to Comment gmrpeabody
gmrpeabody's picture

Rest assured that any sensitive and potentially embarrassing names to this administration will not make list released for the IRS.

Wed, 08/19/2009 - 14:19 | Link to Comment Anonymous
Wed, 08/19/2009 - 11:44 | Link to Comment Anonymous
Wed, 08/19/2009 - 11:45 | Link to Comment economicmorphine
economicmorphine's picture

"At what point with Tim Geithner show a modicum of backbone and actually do the right thing instead of bowing to pressure from any which direction? "

The answer, of course, is never.  Geithner is a bureaucrat.  He is simply doing what bureaucrats do, which is to say, bow to pressure from any which direction.

Wed, 08/19/2009 - 12:51 | Link to Comment Miles Kendig
Miles Kendig's picture

I beg to differ.

Geithner is a bought & paid for political appointee.  The last thing Geithner can be called is a public servant.  He has no idea what the term "loyalty to the institution" means in theory or practice.

Wed, 08/19/2009 - 11:46 | Link to Comment Anonymous
Wed, 08/19/2009 - 12:53 | Link to Comment 100PercentProle
100PercentProle's picture

Where did they get those teeth?

Oh, right... 

Wed, 08/19/2009 - 11:48 | Link to Comment 241
241's picture

I bet that half of Congress, Greenspan and Bernankeare on the list.  That would be the kindling we need for populist outrage.

Wed, 08/19/2009 - 11:50 | Link to Comment Anonymous
Wed, 08/19/2009 - 11:52 | Link to Comment Phil Gramm
Phil Gramm's picture

We here at UBS are delighted with the flexibility and sensability the IRS has shown. Releasing the names of all 52,000 of our clients accused of tax evasion would be devastating.

Executives, politicians, bankers, business owners, actors, musicians, professional athletes, and many more people would be outed. Most of these people are role models and their reputations should not be stained simply because of a bit of tax evasion.

In addition, such a scandal would make the headlines of the newspapers and tabloids for months to come. If you are tired of the media coverage of the death of Michael Jackson, this would be ten times worse. Ask yourself, is it really worth it to ruin the lives of these people?

Finally, I would also confirm that if UBS failed, it would indeed cause the collapse of the world economy. There would be great destitution that could not be undone. In other words, don't mess with UBS!

-- Phil

Wed, 08/19/2009 - 11:57 | Link to Comment Anonymous
Wed, 08/19/2009 - 12:01 | Link to Comment jdoo
jdoo's picture

We have market liftoff...

AXL at full thrust

Wed, 08/19/2009 - 12:02 | Link to Comment Anonymous
Wed, 08/19/2009 - 12:13 | Link to Comment Hostiss
Hostiss's picture

Yeee , sure... the core of the solution is the moral aspect of the possible consequences...

Wed, 08/19/2009 - 12:15 | Link to Comment Raymond Shaw
Raymond Shaw's picture

USD/CHF has been stuck in a range since mid-may.  Next direction likely is up to 1.0950 levels.  As for the person who said that most Swiss banks dont' do business in the US, he surely forgot Credit Suisse.  UBS is not the only bank to work in the US.

Anyway, it's not what happened to those handful that will dictate the fund outflows from Switzlerland, but what the sentiment becomes of other offshore and numbered account holders regarding the safety issues of having an account in that country.  Simples.  Hunting after Switzerland is just another populist outrage.  If they really want to get serious they should start looking at the Caymand Islands where a two thirds of the worlds wealth is parked in terms of legal jurisdiction.

Wed, 08/19/2009 - 12:25 | Link to Comment Anonymous
Wed, 08/19/2009 - 12:34 | Link to Comment Anonymous
Thu, 08/20/2009 - 01:24 | Link to Comment Frank Owen
Frank Owen's picture

Giggity giggity

Wed, 08/19/2009 - 12:34 | Link to Comment zombiebank
zombiebank's picture

So only 10% of the tax evaders have to pay the price.  I suppose we now know who the other 90% are....politicians and friends of politicians.  I think UBS should have said "all or none!"  Where do we get the full list?

 

Wed, 08/19/2009 - 12:38 | Link to Comment Anonymous
Wed, 08/19/2009 - 12:42 | Link to Comment gridlocked
gridlocked's picture

Someone needs to ask Obama on national tv at a town hall how it was decided that 47,000 tax cheats needed to be protected while 5,000 will be dealt with. This is no different than bailing out the country's largest banks (the most responsible for our current situation) and letting the 80 or so banks that have failed this year go to the dogs.

Where is the transparency in this?

Wed, 08/19/2009 - 13:04 | Link to Comment OBRon
OBRon's picture

Remember Set Theory back in grade school?

The intersection between UBS rolls and DNC membership is 47,000.

Pretty simple, actually.

Wed, 08/19/2009 - 21:56 | Link to Comment Anonymous
Wed, 08/19/2009 - 12:44 | Link to Comment Anonymous
Wed, 08/19/2009 - 13:09 | Link to Comment Milton
Milton's picture

Me thinks that story about the 130 million credit card numbers is total bullshit. It's just more propoganda for the gov to justify monitor everything internet -- to protect YOU of course.

As for those tax avoiders, hey how about starting with GS who apparently paid 1% tax on their income last quarter, which was done without cheating.

Wed, 08/19/2009 - 12:47 | Link to Comment gridlocked
gridlocked's picture

According to the Reuters story:

 

However, account-holders threatened with disclosure would be able to challenge the move in the Swiss courts, it said.

 


Wed, 08/19/2009 - 12:50 | Link to Comment iknowNOW (not verified)
Wed, 08/19/2009 - 15:43 | Link to Comment B_Movie
B_Movie's picture

?

Wed, 08/19/2009 - 13:25 | Link to Comment jedwards
jedwards's picture

Apparently there is no fucking moral hazard too hazardous for Geithner to navigate and brush under a rug.  Fuck him for letting 90% of those tax cheats from getting away.  Seriously, fuck him and the level of disgust I feel for him is unprecedented.

Wed, 08/19/2009 - 13:29 | Link to Comment Anonymous
Wed, 08/19/2009 - 13:36 | Link to Comment waterdog
waterdog's picture

The amount of potential money owed on the 5,000 accounts probably exceeded the gross amount of deposits on the other 50,000+. No feather in no cap for anything under $2.3 billion due. There are only so many hours in a day. Probably half these people have one foot in the grave and the other on a banana peel. Not all US money in a Swiss account is illegal. A person's account may be in the mix of target accounts, but a check for a tax return listing the interest earned from the Swiss account and some foreign income earned would get a person removed from the list. Even though the income reported is less than 50% of what was actually earned.

The secrecy of the Swiss bank account was only in the movies.

Wed, 08/19/2009 - 14:25 | Link to Comment Anonymous
Wed, 08/19/2009 - 13:44 | Link to Comment Anonymous
Wed, 08/19/2009 - 14:32 | Link to Comment Anonymous
Wed, 08/19/2009 - 15:10 | Link to Comment Arm
Arm's picture

This could hit UBS quite a lot.  52,000 potential accounts (circa 5,000 confirmed).  They are private banking, so I will venture that $500k is a fair number for each

52k x $500k = $26 Billion

Assuming 100% drawdown, you are talking about 10% of UBS deposit base leaving.  Depending on the unwind period that is dangerously close to bank-run levels.

 

Wed, 08/19/2009 - 15:31 | Link to Comment Anonymous
Wed, 08/19/2009 - 15:43 | Link to Comment gridlocked
gridlocked's picture

The 5,000 that are being given up (there is no evidence other than a statement that these are the largest 5,000) will fight the disclosure in Swiss Courts forever.

 

This is the tip of the iceberg anyway. How many more banks in tax havens are holding hundreds of billions? Lichtenstein, Cayman Islands, Bahamas, Singapore?

Wed, 08/19/2009 - 15:53 | Link to Comment Anonymous
Wed, 08/19/2009 - 16:26 | Link to Comment Anonymous
Wed, 08/19/2009 - 16:45 | Link to Comment Arm
Arm's picture

Stop the presses TD!!!

Boomberg: Swiss Government Decides to Sell Stake in UBS Immediately

http://bloomberg.com/apps/news?pid=20601087&sid=ahHxThBKIivc

Is UBS still one of the largest counterparties for derivative transations? What can happen if 10% of the deposit base flees / is prosecuted, while the remaining 90% wonders if they are next. While at the same time the government dumps 6 billion CHF of in shares (about 10% of marketcap)

Wed, 08/19/2009 - 18:56 | Link to Comment Jeanbon
Jeanbon's picture

The Swiss Gov. just sold it's UBS stake, to Investors

swiss newspapers reporting.

Wed, 08/19/2009 - 19:04 | Link to Comment Jeanbon
Jeanbon's picture

After Stock Markets where able to rebound between 50 & 100 %

from their march09 lows, UBS lost about 3Bln swissis

in H1. There is still no E below the P, but so called Investors

are willing to buy that crap.

The Gov. held about 9 % of the company, so it will be 

interesting to see who owns more than 3 % now, since

it has to be disclosed to public 

 

Wed, 08/19/2009 - 22:41 | Link to Comment Anonymous
Thu, 08/20/2009 - 02:26 | Link to Comment Anonymous
Thu, 08/20/2009 - 06:13 | Link to Comment Anonymous
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