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More details are emerging about the agreement between the U.S. Justice Department and UBS, the Swiss bank accused of helping wealthy Americans evade taxes -- a case that's been bandied about in South Florida's U.S. District Court and that has attracted the two nations' top diplomats. USA Today reports that 4,450 cheaters will be named by the bank and targeted for criminal prosecution.
Diplomats went down to the wire in their effort to avoid a trial in Miami earlier this month. The 4,450 number is about what was expected, and though it's less than 10 percent of the dirty accounts, these might be the pick of the litter -- cases that are big and present a high probability of victory for criminal prosecutors. That is, assuming you believe IRS Commissioner Douglas Shulman:
An estimated 52,000 UBS accounts have some link to U.S. customers. But Shulman said some of those owners had previously disclosed their holdings to the IRS and had paid taxes over the years. He said the IRS all along wanted the 4,450 accounts targeted by the agreement because they had the most potential evidence of tax evasion.
It may seem we don't have much choice but to believe Shulman, but the real test is going to be whether the months to come bring indictments -- or at least huge settlements -- with obscenely wealthy Americans. A bit of schadenfreude tonic to treat the nation's Madoff hangover.