Important information

The IRS has a longstanding voluntary disclosure practice to encourage US taxpayers to bring themselves voluntarily into full compliance with the US tax laws. This practice remains in place and available to US taxpayers who may have US tax return filing or other disclosure obligations as a result of maintenance of an offshore account at UBS even though the IRS’s special penalty initiative for voluntary disclosure requests announced on March 23, 2009 has since expired on October 15, 2009. Participation in the IRS’s longstanding voluntary disclosure practice also generally eliminates the risk of criminal prosecution.

As a general matter, in order to take advantage of the IRS’s voluntary disclosure practice, a US taxpayer must make a voluntary disclosure to the IRS before the IRS identifies the taxpayer’s potential non-compliance with US tax laws based on the IRS Treaty Request, or through a civil examination, criminal investigation or other means. As explained by the IRS in subsequent guidance, there is still an opportunity for taxpayers to make a voluntary disclosure, but that opportunity will be lost upon the provision of the account data to the IRS in response to the Treaty Request. Accordingly, if clients are considering making a voluntary disclosure, it is important to do so now. The IRS has stated that a voluntary disclosure will be considered timely as soon as a taxpayer identifies himself and expresses an intent to disclose, even if the taxpayer has not yet completed amended or delinquent returns. For details and further information on the IRS’s voluntary disclosure practice, please visit the IRS website at: http://www.irs.gov/newsroom/article/0,,id=206012,00.html?portlet=7.

Upon request, UBS will provide clients with account information that they may need in order to make a voluntary disclosure free of charge. Please indicate that you require the documents for the voluntary disclosure. However, as stated above, these documents are not needed to initiate the voluntary disclosure process.