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“The Internal Revenue Service is seeking to force UBS Group AG to turn over records on an account in Singapore held by a U.S. citizen, potentially opening a new front against offshore tax evasion beyond Switzerland.
The IRS last month asked a federal judge in Miami to force UBS, the largest Swiss bank, to produce documents on Ching-Ye Hsiaw, who lives in China. The judge on Wednesday told UBS to show up in court on March 31 to explain why it has refused to supply the account records.
“They’re holding UBS hostage in the U.S. by saying you subjected yourself to U.S. jurisdiction, now produce these records outside the U.S.,” said Jeff Neiman, a former federal prosecutor. “It’s setting up a showdown of Singapore secrecy versus the U.S. need to enforce its tax laws.”
Singapore will lift banking confidentiality when foreign authorities ask it to do so and when the law is used to shield criminal activities, according to a person with direct knowledge of the city-state’s bank-regulation framework who asked not to be named because of an ongoing court case.
“No jurisdiction is off limits,” Acting Assistant Attorney General Caroline D. Ciraolo, who oversees the U.S. Justice Department’s Tax Division, told the Federal Bar Association in a speech Friday. She said “our investigations of both individuals and entities are well beyond Switzerland at this point.”
UBS spokesman Gregg Rosenberg declined to comment on the case. Hsiaw couldn’t be reached for comment.