The Justice Department has filed papers seeking an order from a federal court in Miami, authorizing the Internal Revenue Service to request information from banking and financial concern UBS AG regarding U.S. taxpayers using Swiss bank accounts to evade taxes. The Justice Department is seeking permission to allow the IRS to serve a "John Doe" summons on the bank. In June, former UBS banker Bradley Birkenfeld pleaded guilty to conspiring to defraud the IRS by assisting UBS clients in avoiding U.S. reporting requirements on income in Swiss bank accounts. Birkenfeld admitted to conspiring with an American billionaire real estate developer, Swiss bankers and co-defendant Mario Staggl to help the developer evade paying $7.2 million in taxes by helping him conceal $200 million of assets in Switzerland and Liechtenstein. According to Birkenfeld,, UBS employees assisted wealthy U.S. clients in hiding offshore assets by creating sham entities and then filing IRS forms falsely claiming that the entities were the owners of the accounts. He also claimed that UBS had approximately $20 billion of assets under management in undeclared accounts for U.S. taxpayers. If approved, the summons would mandate UBS to produce records that identify U.S. taxpayers with accounts at UBS in Switzerland who elected to have their accounts remain hidden from the IRS.

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