Secret Swiss bank accounts may not be so secret anymore.
The Justice Department filed suit in Miami federal court Thursday seeking to force Swiss banking giant UBS to name 52,000 U.S. customers with Swiss accounts totaling $14.8 billion.
The IRS action comes on the heels of a massive settlement Wednesday in which UBS moved to avoid a criminal prosecution that would likely have threatened its survival.
The bank entered into a deferred prosecution agreement, providing for it to pay $780 million to the United States and to name 250 to 300 U.S. customers who are suspected of committing U.S. tax fraud under Swiss government guidelines. The Swiss government turned over those clients' names to the U.S. shortly after the agreement was signed.
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But the giant customer list the IRS wants is another matter. UBS said Thursday it will ''vigorously contest'' efforts to enforce the ''John Doe'' civil summons covering 52,000 U.S. clients. UBS said it has solid defenses under U.S. and international laws as to why the accounts should remain confidential.
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