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By Christian Hartmann, ReutersUBS offices in Zurich. The Swiss bank, with governmentsupport, is using all legal means to avoid being forcedinto naming names of account holders suspected ofevading U.S. taxes.
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ByKevin McCoy, USA TODAY
One is a U.S. business owner who hid atax-evasion scheme "well into the sevenfigures."Another is an elderly American who keptmoney in an offshore account over fear forthe security of the U.S. banking system.And then there are the children of parentswho survived the Holocaust and established aforeign trust account on their behalf.Their attorney says all had undeclared bankaccounts at UBS,(UBS)the Swiss bankinggiant sued Thursday by U.S. authorities in anescalated demand for the identities of ownersof approximately 52,000 such accounts in which Americanssecretly held at least $14.8 billion.They're also among a recent rush of American UBS customerswho contacted the IRS about their accounts, hoping to gainleniency for their failure to pay years of federal taxes on thesecret holdings."The rush is on," says Robert McKenzie, a Chicago attorneywho's representing the three UBS account holders plus 14others seeking similar tax settlements regarding accounts at theSwiss bank.The IRS' message is clear: "You better come in now before yourname comes out," said McKenzie, who declined to identify hisclients but agreed to discuss general outlines of their cases.The developments are part of a historic legal struggle that hascracked Switzerland's renowned reputation for banking secrecyand cast a spotlight on what a 2008 Senate hearing identified as$100 billion in annual tax evasion by American owners of foreignaccounts.U.S. authorities filed the civil lawsuit in Miami, one day afterreaching a deferred-prosecution deal in which UBS agreed to a$780 million settlement of criminal charges it helped Americancustomers evade federal taxes. The agreement required thebank to turn over identities of some of those clients.Thursday's civil lawsuit asked a federal court to enforceso-called John Doe summonses served on UBS last year for thenames of the undeclared account owners, along with details oftheir holdings.The court demand also cited roughly 52,000 suspect accounts,up from 19,000 federal authorities alleged last year.Federal authorities upped the legal ante after UBS' criminal caseacknowledgement of a 2000-2008 scheme in which its bankersused encrypted laptop computers and counter-surveillancetactics during trips to the U.S. in which they helped Americanclients evade taxes.