According to the complaint, from 2001 through 2007, Rubinstein dealt with UBS bankers to buy and sell securities worth more than 4.5 million Swiss francs, or about $4 million; to convert investments from dollars to British pounds, and to deposit and transfer funds into and out of the UBS account.
The government also alleged that Rubinstein deposited and sold more than $2 million in South African Krugerrands through his UBS account.
Robert E. Panoff, an attorney for Rubinstein, could not immediately be reached for comment.
Rubinstein is slated to be sentenced Sept. 30 before U.S. District Judge Marcia G. Cooke. He faces up to three years in prison and a maximum fine of $250,000.
He also agreed to pay a penalty amounting to 50 percent of the top value of his bank account for failing to disclose he had an offshore account with more than $10,000, as required by U.S. law. That penalty could cost millions of dollars.
When he was arrested in April, Rubinstein had to turn over his passport. He has been wearing an ankle bracelet and must stay home at night. He also had to turn over the keys to his boat. He remains free on $12 million bail.
UBS is in the process of closing all offshore accounts with U.S. clients. That, combined with the IRS's recent clarification of guidelines for making voluntary settlements related to offshore bank accounts, is fueling a rush to fess up to tax violations.
"We're seeing a huge spike in the number of people coming forward to make voluntary disclosures," said William M. Sharp, a tax attorney with Sharp & Associates in Tampa.
In UBS's deferred prosecution agreement with the U.S. government, the bank admitted to helping U.S. taxpayers hide accounts from the IRS and agreed to pay $780 million to the U.S. government. And in a stunning blow to Switzerland's time-honored insistence on bank secrecy, UBS agreed to provide the United States with the names and account information of the 250 to 300 U.S. customers.
To comply with Swiss law, UBS provided information on those clients to Swiss banking authorities, who, in turn, decided it could be released to the United States because those account holders appeared to have committed U.S. tax fraud under Swiss legal guidelines.
However, the IRS is pressing forward in a civil suit against UBS that seeks to force the bank to disclose the identities of 52,000 additional U.S. customers of UBS with Swiss accounts totaling $14.8 billion. UBS is fighting that broader effort.
A federal trial is set for July 13 to 15 to hear testimony from UBS and the federal government to decide whether the bank must turn over the additional records. UBS has said doing so would violate the laws of its own country.
Switzerland agreed in a new tax treaty in June to broaden the circumstances under which it will share tax information with the United States, bolstering the Obama administration's efforts to crack down on offshore tax cheats.
The veil on UBS private banking operations began to lift in May 2008 when federal prosecutors in Fort Lauderdale unsealed an indictment against former UBS banker Bradley Birkenfeld.
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