Bank giant UBS must name U.S. clientele

Some rich Americans thought to be tax cheats

NEW YORK TIMES NEWS SERVICE
2:00 a.m. August 13, 2009

Swiss banking giant UBS and the Justice Department reached an accord yesterday that would force the bank to disclose the names of certain American clients suspected of tax evasion.

While it is unclear how many names will be released, the agreement could result in scores of wealthy Americans with offshore accounts having their identities revealed to the Internal Revenue Service. Many could face charges of tax evasion as well as big fines and back taxes.

H. David Rosenbloom, a former Treasury official, said he thought UBS would turn over about 5,000 names, probably those with the largest accounts who had been visited in the United States by Swiss-based bankers.

UBS and the Swiss government have been fighting efforts by the Justice Department to force it to disclose the names of 52,000 American clients of UBS suspected of offshore tax evasion. The moves have threatened to erode Swiss financial-secrecy laws — the bulwark of the Swiss economy — and have shaken UBS and other private banks around the globe. The dispute also escalated into high-level talks with Swiss and U.S. officials in Washington.

In February, UBS agreed to pay $780 million to settle charges that it had helped wealthy Americans evade taxes on nearly $20 billion hidden in offshore accounts. One day later, the Justice Department filed a civil suit seeking to force UBS to disclose 52,000 client names.

Of the names on the agency's original list, prosecutors are focused on several thousand Americans with offshore accounts containing tens of millions to hundreds of millions of dollars, said a government official briefed on the matter.

As the settlement talks have played out, a number of wealthy Americans have approached the IRS to disclose their offshore accounts, in exchange for reduced penalties under an IRS program that ends Sept. 23.
UBS had fiercely resisted disclosure, arguing that doing so would cause it to violate Swiss banking laws.

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