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Today's deadline for Swiss banking giant UBS to turn over 4,450 names of U.S. clients with undisclosed assets—after a year marked by legal battles to protect the information—is a mile marker in a changed landscape of disclosure and transparency, practitioners tell BNA. The UBS investigation is part of a concerted crackdown by the United States and other governments that has led to a profound alteration in the ability of taxpayers to hide assets overseas, they tell BNA. Information continues to pour in from a special IRS program seeking disclosure of those assets in 2009, and taxpayers continue to seek acceptance into a pre-existing voluntary disclosure program that still is available to those who want to come into compliance, practitioners say.
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