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Robert Trigaux

UBS clients vs. IRS: Tampa lawyer in thick of it



Williamsharpattorney Wake up and good morning. Wealthy clients of Swiss bank UBS AG are coming forward to make amends with tax authorities, the Wall Street Journal reported this week. And one lawyer helping clients come forward is Tampa's William M. Sharp Sr., who operates an international tax practice. Sharp grew up in South Bend, Ind., and became interested in accounting and tax law because his father was an accountant.

Sharp has been working for Swiss banking clients for 15 years, the Journal says in this story. Sharp's role, also noted in this Washington Post story, is just one piece of a fascinating look at the IRS crackdown on UBS and its wealthy U.S. clients who, reports say, have been busy stashing money overseas to avoid federal taxes. Needless to say, a lot of it has happened here in Florida. Here's the quick background:

* UBS has been under pressure from the U.S. government since June, when a former UBS banker named Bradley Birkenfeld pleaded guilty to helping an American real estate developer hide $200-million of assets and evade $7.2-million of taxes. Birkenfeld has been cooperating with U.S authorities in a widening investigation that led to the federal indictment of one of UBS's top executives.

* The indictment by a grand jury in Florida, unsealed this month, revealed the investigation reached the highest levels of UBS's Zurich headquarters when Raoul Weil, the chief of UBS's private bank, was accused of conspiring with a host of others at the bank to market Swiss bank secrecy to American clients and help them dodge taxes. A lawyer for Weil denied the charges and said he would seek vindication. Meanwhile, UBS has given U.S. authorities the names of about 70 clients who wired money from UBS accounts in the United States to UBS accounts in Switzerland.

When UBS clients learned that Birkenfeld was providing information to the IRS, "that's what opened the floodgate," Sharp told the Journal. In recent months, Sharp has flown from Tampa to Zurich to review some of the world's most secretive and confidential private-bank client records. The 55-year-old typically holes up in UBS's private-bank headquarters on the Paradeplatz, the newspaper says, the center of the private-banking world. "We've got to have access to all that nitty-gritty source information," said Sharp of Tampa's Sharp & Associates. "In addition to that, we've got to show the government that the money is from a legal source."

Sharp's legal firm is clearly focused on working with UBS clients. The law firm's Web site carries specific articles penned by Sharp and others counseling potential tax avoiders to come clean, as this example shows:

"A window of opportunity exists for these taxpayers to come clean through the voluntary disclosure process, thereby limiting the criminal liability exposure and potentially
reducing the overall penalty exposure associated with past years’ noncompliant conduct."

-- Robert Trigaux, Times Business Columnist

[Last modified: Tuesday, June 1, 2010 11:23am]


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