US Confirms Settlement with Swiss in UBS Offshore Account Battle

IRS Commissioner Douglas Shulman confirmed Wednesday that the U.S. has reached a settlement agreement with the Swiss government regarding the ongoing UBS battle over the names of U.S. account holders with UBS.

Shulman stated that the U.S. has initialed the agreement, but will not release any details until the Swiss government signs it.  Details may not be released until next week.  In a statement, Shulman confirms, if somewhat cryptically, that the settlement “protects the United States government's interests.”  

Although no official details have been released, it is rumored that as many as 10,000 names may be turned over to the IRS.  While this is less than 20% of the 52,000 names the IRS was seeking, it is still a victory for the government.  Presumably, the settlement agreement will have some protection in place in the event named taxpayers decide to sue UBS in Swiss court for violation of Swiss banking law.

The details of this settlement will likely set the tone for IRS/DOJ efforts to obtain names of U.S. taxpayers from other foreign banks.  Depending on the terms of the agreement with the Swiss government, the agreement may pave the way for the U.S. to go after other Swiss banks.