Tax evasion in the United States unlawful gains as income when filing annual tax returns (see e.g., "James v. United States") although such income is typically not reported. Suspected lawbreakers, most famously Al Capone, have been successfully prosecuted for tax evasion when there was insufficient evidence to try them for their non-tax related crimes. Reporting illegal income as earned legitimately may be illegal money laundering. In the United States, the IRS estimate of the 2001 tax gap was $345 billion. For 2006, the tax gap is estimated to be $450 billion. A more recent study estimates the 2008 tax gap in the range of $450 to
UBS tax evasion controversies enabling tax avoidance. In February 2015, UBS announced that it was being investigated by the Office of the U.S. Attorney for the Eastern District of New York and the Securities Exchange Commission over new allegations that UBS facilitated tax evasion by its U.S. clientele. The focus of the investigation is the possible sale of bearer bonds. Bearer bonds are a type of unregistered security that provide a degree of anonymity to the owner as they can be transferred anonymously when held in paper form, thus enabling tax evasion as such transfers would allow the owner to conceal their financial assets.