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The Internal Revenue Service and the Department of Justice have entered into an agreement that will result in the IRS receiving an unprecedented amount of information on United States holders of accounts at the Swiss bank UBS. Highlights of agreement include:

--Pursuant to a treaty request, the IRS will receive information on accounts of various amounts and types, including bank-only accounts, custody accounts in which securities or other investment assets were held and offshore company nominee accounts through which an individual indirectly held beneficial ownership in the accounts.

--If the results are not satisfactory to the IRS, it may resume other judicial remedies to gather additional information.

--The Swiss government will direct UBS to notify account holders that their information is included in the IRS treaty request. It is expected that these notices will be sent on a rolling basis with some being sent over the coming weeks and others over the coming months. Receipt of this notice will not by itself preclude the account holder from entering the IRS' Voluntary Disclosure Program.

--The Swiss government will also entertain requests for similarly situated accounts at other Swiss banks.

--Individuals whose information is obtained by the IRS through this process will not be eligible for the Voluntary Disclosure Program.

IR 2009-75

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