UBS and the governments of the U.S. and Switzerland are in talks to settle a major tax-evasion case that could require the Swiss bank to reveal some of the 52,000 account-holder names the U.S. has brought, reports The Wall Street Journal.
The talks would not reveal all of the names, but those mentioned could lead to criminal prosecutions of U.S. clients. UBS could turn over some names to the IRS if actual fraud under Swiss law could be cited in the accounts.
Evidence for fraud is one way for Swiss banks to disclose names without violating secrecy. In February, the Justice Department sued to gain access to the 52,000 accounts. But some 7,000 accounts are more likely to be subject to the settlement because they are tied to offshore companies and trusts—which are more susceptible to fraud.
Chief Executive Oswald Grübel, who took over in February, said the IRS’s demand for information “puts UBS in an untenable position, caught between the laws of two sovereign nations.”