UBS conceded last week that it had “participated in a scheme to defraud the United States and its agency the IRS” by hiding U.S. taxpayer accounts. In the overt acts enumerated in Exhibit B, “on or about July 6, 2000, a Manager authorized Bankers to refer United States clients to outside lawyers and accountants to create offshore structures to conceal from the IRS United States’ clients UBS accounts, while knowing that creating these structures constituted helping the United States Clients commit tax evasion.” All that concealing and evading continued until 2007.

The bank will pay the U.S. $780 million, eventually. And the U.S.—on behalf of the IRS—is seeking names, lots of names, attached to UBS accounts. Possibly 52,000 names are involved, kept secret under Switzerland’s centuries-old banking rules. The bank was served on July 21, 2008. “UBS failed to appear on August 8, 2008,” last week’s summons reads. “To date, UBS has failed to comply in full with the summons.”

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