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The UBS numbers, as reported by the WSJ, don’t make a lot of sense to me:

UBS AG will hand over some 4,450 names of U.S. account holders as part of a U.S.-Swiss tax-evasion settlement and investigation that could produce in total 10,000 account identities, according to people familiar with the situation…

Aside from the account identities being turned over by UBS, some 5,000 names are expected to be produced through a special IRS amnesty program where UBS clients acknowledge unpaid income tax.

How is this IRS amnesty supposed to work? I was under the impression that they’ve tried this already: “if you fess up now, before we get our list of 4,450 names, and you’re on the list, then we won’t hit you with massive penalties — but if you don’t fess up and you’re on the list, then we’ll be much harsher”.

But 4,450 is a lower number than expected, and I’m pretty sure that substantially all of UBS’s clients will opt to take their chances rather than voluntarily going to the IRS. If they get caught, then so be it. But if they don’t, they’re basically home free: after all this back-and-forth, no one has any appetite to go through the whole thing all over again.

Indeed, there’s a possible upside to this whole affair for UBS: if I were a private-banking client of a major Swiss bank which wasn’t UBS, I’d be inclined to move my funds to UBS right now just on the grounds that lightning is most unlikely to strike twice. Not that UBS has any interest in condoning US tax-evasion any more, of course. Oh no.

Source: UBS: Where Will the Other 5,500 Names Come From?