IRS asks tax evaders: Who assisted the taxpayer in opening the bank account?

According to legal experts, the IRS plans to expand its investigation of wealthy Americans suspected of evading taxes through offshore bank accounts to include bankers, accountants, attorneys and others who may have advised the account owners.

Summaries of questions that federal investigators ask owners who disclose their offshore assets at Swiss banking giant UBS and other foreign banks under an IRS voluntary disclosure program focus directly on the intermediaries. The queries, provided to USA TODAY by lawyers for UBS clients, include:

•Who told the taxpayer about the bank account?
•Who assisted the taxpayer in opening the bank account?
•Who prepared the tax returns?

The IRS said the summaries seem to be a compilation of questions to judge eligibility for the disclosure program, which expires September 23. Besides, a form letter the IRS issued last week for use with offshore account owners seeks names, dates and locations of meetings with "independent advisers/investment managers."

The main focus of the ongoing IRS investigation is on an internationally watched battle with UBS over the names and account data for as many as 52,000 wealthy American clients suspected of tax evasion. Justice Department lawyers argue the information must be turned over as the owners have evaded millions of dollars in federal taxes with UBS assistance.

UBS has contended that disclosing the customer data would violate Swiss banking secrecy laws. The Swiss government has raised the possibility that it would seize the data to prevent any handover. In addition, both sides last week announced an agreement in principle that is scheduled to be submitted to a federal judge in Miami on Friday.